Bishop v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 4/3/2017 for defendant to file a response to plaintiff's opening brief. The Court's scheduling order is modified accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 2/14/2017. (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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DEBORAH ANN BISHOP
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:16-CV-00741-EPG
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S OPENING BRIEF

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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 Opening Brief be extended for approximately forty-five

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(45) days from February 16, 2017, to April 3, 2017 due to current workload demands. This is

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Defendant’s first request for extension. Good cause exists as counsel for Defendant has

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numerous pending responses due at or around the same time and a Ninth Circuit responsive brief

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due. Additional time is also required because counsel for Defendant will not be able to complete

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the review process for new attorneys due to scheduling conflicts and upcoming scheduled leave

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of reviewing counsel for Defendant from March 10, 2017 to March 21, 2017. As such,

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Defendant respectfully requests additional time to respond to Plaintiff’s Opening Brief in order
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to adequately research and analyze the issues presented by Plaintiff. Defendant makes this

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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
accordingly.

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Respectfully submitted,

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Dated: February 10, 2017

/s/ *Young Cho
(*as authorized by email on February 9, 2017)
YOUNG CHO
Attorney for Plaintiff

Dated: February 10, 2017

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

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/s/ Tina Naicker
Tina 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 from February 16, 2017, to April 3, 2017 for Defendant to respond to Plaintiff’s Opening
Brief. The Court’s Scheduling Order is modified accordingly.
IT IS SO ORDERED.

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Dated:

February 14, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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