Ondracek v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER for an Extension of Time. Defendant is granted an extension of time, up and including November 7, 2016, to file an opposition brief. Plaintiff may file an optional reply brief on or before November 28, 2016. Order signed by Magistrate Judge Sheila K. Oberto on 9/1/2016. (Timken, A)

1
2
3
4
5
6
7

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
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]

8
9

Attorneys for Defendant
UNITED STATES DISTRICT COURT

10
EASTERN DISTRICT OF CALIFORNIA
11
12

) Case No.: 1:15-cv-01308-SKO
)
) STIPULATION AND ORDER
) FOR AN EXTENSION OF TIME
)
)
)
)
)
)
)
)

Mark Steven Ondracek,
13
Plaintiff,
14
vs.
15
16
17

CAROLYN W. COLVIN, Acting
Commissioner of Social Security,
Defendant.

18
19

Defendant CAROLYN W. COLVIN, Acting Commissioner of Social Security, through

20
21
22
23
24
25
26
27
28

her counsel of record, hereby moves the Court to extend the time by 60 days from September 7,
2016, to November 7, 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 the
undersigned agency counsel is leaving the Social Security Administration. The agency must
reassign the case to another agency counsel who will need additional time to become familiar
with the facts and issues of the case before briefing. Counsel apologizes to the Court and
Plaintiff for any inconvenience that this may cause.
//

Stip. & Order for Ext.; 1:15-cv-01308-SKO

1

1

Respectfully submitted,

2
3

Dated: August 31, 2016

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

4
5
6

By

7
8

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

9
10

Date: August 31, 2016
MELISSA NEWEL
Newel Law

11
12

/s/ Melissa Newel*
MELISSA NEWEL
[*By email authorization on August 30, 2016]
Attorney for Plaintiff

13
14
15
16

ORDER

17
18

Based on the above stipulation of the parties, IT IS HEREBY ORDERED that:

19

1.

20

Defendant is granted an extension of time, up and including November 7, 2016, to

file an opposition brief; and

21

2.

Plaintiff may file an optional reply brief on or before November 28, 2016.

22
IT IS SO ORDERED.
23
24

Dated:

September 1, 2016

/s/

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

25
26
27
28

Stip. & Order for Ext.; 1:15-cv-01308-SKO

2

.