Ornellas v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 4/4/2016 for receipt of defendant's opposition brief, with plaintiff's reply brief, if any, due within fifteen days the filing of the opposition. Order signed by Magistrate Judge Erica P. Grosjean on 2/26/2016. (Rooney, M)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
HEATHER M. MOSS, DCBN 995773
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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) Case No.: 1:15-cv-00730-EPG
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) STIPULATION AND ORDER
) FOR AN EXTENSION OF TIME
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NORMA JEAN ORNELLAS,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN, Acting
Commissioner of Social Security,
Defendant.

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Defendant CAROLYN W. COLVIN, Acting Commissioner of Social Security, through
her counsel of record, hereby moves the Court to extend the time from March 4, 2016, to April 4,
2016, for Defendant to file her opposition, and to extend the remaining case deadlines
accordingly.
There is good cause for extending the case deadlines because Counsel has an unusually
robust caseload, which includes active discovery in an employment matter and Bankruptcy
representation. Additional time is needed to responsibly respond to Plaintiff’s contentions.
Counsel apologizes to the Court for any inconvenience that this may cause and assures all parties
that she has taken every action to minimize it.

Stip. & Order for Ext.; 1:15-cv-00730-EPG

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Respectfully submitted,

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Dated: February 25, 2016

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Heather M. Moss
HEATHER M. MOSS
Special Assistant U.S. Attorney
Attorneys for Defendant

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Date: February 25, 2016

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JACQUELINE A. FORSLUND
Attorney at Law

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/s/Jacqueline A. Forslund*
JACQUELINE A. FORSLUND
[*By email authorization]
Attorney for Plaintiff

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ORDER
Pursuant to the stipulation, Defendant’s opposition shall be filed no later than April 4,
2016. Any reply shall be filed within fifteen days of the filing of the opposition.

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IT IS SO ORDERED.

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Dated:

February 26, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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Stip. & Order for Ext.; 1:15-cv-00730-EPG

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