Banuelos v. Commissioner of Social Security

Filing 27

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 4/10/2017 for defendant to file a response to plaintiff's motion for summary judgment, with all other deadlines extended accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 4/5/2017. (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 for an

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additional three days from April 7, 2017 to April 10, 2017. This is Defendant’s third request for

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extension. Good cause exists as counsel for Defendant was unexpectedly out of the office last

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week and anticipates taking further leave this week, including on April 7, 2017, the current

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deadline for Defendant’s response, in order to take her mother to the hospital for an urgent

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medical issue. Counsel for Defendant is the primary caregiver for her elderly and disabled

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mother. Due to the unexpected absences, counsel needs additional time to adequately research,

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analyze, and respond to the issues raised in Plaintiff’s Motion for Summary Judgment.
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Defendant makes this request in good faith with no intention to unduly delay the

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proceedings. Defendant will diligently make the new deadline. The parties further stipulate that

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the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: April 4, 2017

/s/ *Cyrus Safa
(*as authorized by email on April 4, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: April 4, 2017

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

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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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By

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ORDER

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For the reasons provided in the parties’ stipulation, good cause appears for an extension
of time for responding to Plaintiff’s Motion for Summary Judgment for until April 10, 2017. All
other deadlines in the scheduling order are modified accordingly.
IT IS SO ORDERED.

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Dated:

April 5, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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