Banuelos v. Commissioner of Social Security

Filing 25

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 4/7/2017 for receipt of defendant's opposition brief, with plaintiff's reply, if any, due by 4/24/2017. Order signed by Magistrate Judge Erica P. Grosjean on 3/2/2017. (Rooney, M)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
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,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
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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March 8, 2017, to April 7, 2017 due to current workload demands. This is Defendant’s second

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request for extension. Good cause exists as counsel for Defendant has a Ninth Circuit responsive

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brief due to the U.S. Attorney’s Office on or around the same time as the current deadline. In

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addition, counsel for Defendant needs additional time to complete the agency’s review process

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for new attorneys and due to scheduling conflicts with anticipated leave from March 10-21,

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2017, counsel will not be able to complete the review process, which requires additional levels of

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review. Defendant respectfully requests additional time to respond to Plaintiff’s Motion for
Joint Stipulation for Extension of Time, Case No. 1:16-CV-00687-EPG

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Summary Judgment in order to adequately research and analyze the issues presented by Plaintiff.

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Defendant makes this request in good faith with no intention to unduly delay the proceedings.

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

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accordingly.

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Respectfully submitted,

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Dated: February 28, 2017

/s/ *Cyrus Safa
(*as authorized by email on February 28, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: February 28, 2017

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

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
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 Defendant
an extension of time to file her opposition to Plaintiff’s opening brief. Defendant’s opposition brief
shall be filed no later than April 7, 2017. Plaintiff may file her reply brief no later than April 24,
2017.

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IT IS SO ORDERED.

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Dated:

March 2, 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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