Bishop v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 5/3/2017 for defendant to respond to plaintiff's opening brief, with all other deadlines extended accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 4/3/2017. (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 Defendant to respond to Plaintiff’s Opening Brief be extended for 30 days from

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the current deadline of April 3, 2017 to May 3, 2017. This is Defendant’s second request for

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extension. Good cause exists to grant Defendant’s request for extension. Additional time is

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required as counsel for Defendant has over 45+ active matters, of which five dispositive motions

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are required on or before the current deadline, including Defendant’s opening brief before the

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Ninth Circuit. Due to scheduling conflicts, counsel for Defendant needs additional time to

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complete the agency’s review process and U.S. Attorneys’ process for the Ninth Circuit brief.

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Additionally, counsel for Defendant was recently assigned a document review matter that

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requires immediate attention. As such, Defendant respectfully requests additional time to

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respond to Plaintiff’s Opening Brief in order to adequately research, analyze and respond 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. Defendant will diligently meet the next deadline. The parties

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further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: March 30, 2017

/s/ *Young Cho
(*as authorized by email on March 30, 2017)
YOUNG CHO
Attorney for Plaintiff

Dated: March 30, 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
For the reasons provided in the parties’ stipulation, good cause appears to extend the time

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for Defendant to respond to Plaintiff’s Opening Brief be extended for 30 days from the current

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deadline of April 3, 2017 to May 3, 2017. All other deadlines are extended accordingly.

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IT IS SO ORDERED.
Dated:

April 3, 2017

/s/
UNITED STATES MAGISTRATE JUDGE