Banuelos v. Commissioner of Social Security

Filing 22

Joint Stipulation and Order for extension of time for Defendant to respond to Plaintiffs Motion for Summary Judgment, signed by Magistrate Judge Erica P. Grosjean on 1/26/2017. (Response due by 3/8/2017) (Rosales, O)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ROYA MASSOUMI, CSBN 242697
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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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IRMA PACHECO BANUELOS
Plaintiff,

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vs.
NANCY A. BERRYHILL1,
Acting Commissioner of Social Security,

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Defendant.

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Case No.: 1:16-CV-00687-EPG
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from

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February 6, 2017, to March 8, 2017 due to current workload demands. This is Defendant’s first

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request for extension. Good cause exists as counsel for Defendant has four other pending

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responses due at or around the same time and a Ninth Circuit responsive brief due to the U.S.

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Attorney’s Office shortly thereafter. Defendant respectfully requests additional time to respond

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Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal
Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Acting Commissioner Carolyn W. Colvin as
the defendant in this suit. No further action needs to be taken to continue this suit by reason of the last sentence of
section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).
Joint Stipulation for Extension of Time, Case No. 1:16-CV-00687-EPG

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to Plaintiff’s Motion for Summary Judgment in order to adequately research and analyze the

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issues presented by Plaintiff. Defendant makes this request in good faith with no intention to

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unduly delay the proceedings.

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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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Dated: January 25, 2017

/s/ *Cyrus Safa
(*as authorized by email on January 25, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: January 25, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

/s/ Roya Massoumi
Roya Massoumi
Special Assistant U.S. Attorney
Of Counsel:
TINA L. NAICKER
Assistant Regional Counsel

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Attorneys for Defendant

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Joint Stipulation for Extension of Time, Case No. 1:16-CV-00687-EPG

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ORDER

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For the reasons stated in the stipulation, good cause appears to extend the time for

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responding to Plaintiff’s opening brief from February 6, 2017, to March 8, 2017.

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IT IS SO ORDERED.
Dated:

January 26, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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Joint Stipulation for Extension of Time, Case No. 1:16-CV-00687-EPG

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