Marquez v. Commissioner of Social Security

Filing 11

STIPULATION and ORDER TO EXTEND TIME, signed by Magistrate Judge Erica P. Grosjean on 5/25/2016. (Kusamura, W)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
CHANTAL R. JENKINS, PA SBN 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [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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FRESNO DIVISION
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NANCY ARACELIA MARQUEZ,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

) Case No.: 1:15-CV-01822-EPG
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) STIPULATION AND ORDER TO
) EXTEND TIME
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The parties hereby stipulate by counsel, with the Court’s approval as indicated by

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issuance of the attached Order, that Defendant shall have a first extension of time of 30 days,

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from May 24, 2016 to June 23, 2016, to file the Certified Administrative Record (CAR).

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There is good cause for this extension as the Office of Disability Adjudication and

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Review (ODAR) needs additional time to assemble the CAR for this matter. As such, Defendant

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requests a 30-day extension of time to assemble, produce, and file the CAR. Defendant

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apologizes to the Court for this delay and hereby requests to extend the schedule in this matter.

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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Pena & Bromberg, Attorneys at Law

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Dated: May 24, 2016

/s/ Jonathan Omar Pena*________
JONATHAN OMAR PENA
(as authorized via email on May 24, 2016)
Attorney at Law

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Attorney for Plaintiff

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Dated: May 24, 2016

PHILLIP A. TALBERT
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/ Chantal R. Jenkins_______
CHANTAL R. JENKINS
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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Based on the above stipulation and good cause appearing therein, the Court grants

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Defendant an extension of time to file the Certified Administrative Record in this case. The

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Administrative Record shall be filed no later than June 23, 2016. All other deadlines in the

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Court’s Scheduling Order (ECF No. 5) are adjusted accordingly.

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IT IS SO ORDERED.
Dated:

May 25, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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