Simonian v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER for a Second Extension of Time for Defendant to File Her Responsive Brief: Defendant's request for an extension of time to April 19, 2017, to file an opposition to Plaintiffs Opening Brief is HEREBY GRANTED nunc pro tunc. signed by Magistrate Judge Barbara A. McAuliffe on 4/21/2017. (Herman, H)

1
2
3
4
5
6
7
8
9

PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
JACOB M. MIKOW, CSBN 238045
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA

12

FRESNO DIVISION

13

JON SIMONIAN,

14
15
16
17
18
19

Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

)
)
)
)
)
)
)
)
)
)
)

Civil No. 1:16-cv-00717-BAM
STIPULATION AND ORDER FOR A
SECOND EXTENSION OF TIME FOR
DEFENDANT TO FILE HER
RESPONSIVE BRIEF

20
21

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and

22

with the approval of the Court, that Defendant shall have a second extension of time to

23

Wednesday, April 19, 2017 to file her responsive brief. Defendant apologizes for missing the

24

filing deadline in this case and respectfully requests this additional time as this case was

25

transferred to new counsel who had to review and brief the case. This stipulation and proposed

26

order is simultaneously being filed with the Defendant’s Opposition to Plaintiff’s Opening Brief

27

and the Defendant’s Response to the Court’s Order to Show Cause.

28
1

1

The new due date for Defendant’s responsive brief will be Wednesday, April 19, 2017.

2

Respectfully submitted,

3
Date: April 19, 2017

FORSLUND LAW LLC

4
By:

5
6
7
8

Date: April 19, 2017

/s/ Jacqueline Forslund*
JACQUELINE FORSLUND
* By email authorization on April 15, 2017
Attorney for Plaintiff
PHILIP A. TALBERT
United States Attorney

9
By:

10
11

/s/ Jacob M. Mikow
JACOB M. MIKOW
Special Assistant United States Attorney
Attorneys for Defendant

12
13
14
15
ORDER

16
17

Pursuant to the stipulation of the parties, and good cause appearing, Defendant’s request

18

for an extension of time to April 19, 2017, to file an opposition to Plaintiff’s Opening Brief is

19

HEREBY GRANTED nunc pro tunc.

20
21
22

IT IS SO ORDERED.
Dated:

/s/ Barbara

April 21, 2017

A. McAuliffe

_

UNITED STATES MAGISTRATE JUDGE

23
24
25
26
27
28
2

1
2
3

Stip. to Extend Def.’s Brief

4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3