Thornton v. Commissioner of Social Security

Filing 27

JOINT STIPULATION and ORDER for Extension of Time for Defendant to Respond to Plaintiff's Motion for Summary Judgment signed by Magistrate Judge Gary S. Austin on 7/31/2017. Pursuant to the stipulation of the parties (Doc. 26 ), Defendant's Opposition shall be filed no later than August 4, 2017. Any Reply shall be filed fifteen days after the filing of the Opposition. (Valdez, E)

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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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JENYNE THORNTON,

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Plaintiff,

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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:16-CV-00816-GSA
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 two

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days from August 2, 2017 to August 4, 2017. This is Defendant’s third request for extension.

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

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counsel for Defendant had a death in her family and is attending funeral and prayer services this

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week. As such, Counsel needs additional time to properly respond to Plaintiff’s Motion for

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Summary Judgment. Counsel for Defendant apologizes for the belated nature of this request, but

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did not anticipate seeking an additional extension due to the recent, unexpected death in her

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family. Defendant makes this request in good faith with no intention to unduly delay the
JS for Extension of Time, Case No. 1:16-CV-00816-GSA

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proceedings. 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: July 31, 2017

/s/ *Melissa Newel
(*as authorized by email on July 31, 2017)
MELISSA NEWEL
Attorney for Plaintiff

Dated: July 31, 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
Attorneys for Defendant

ORDER

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Pursuant to the stipulation of the parties (Doc. 26), Defendant’s Opposition shall be filed

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no later than August 4, 2017. Any Reply shall be filed fifteen days after the filing of the

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Opposition.

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IT IS SO ORDERED.

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Dated:

July 31, 2017

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time, Case No. 1:16-CV-00816-GSA

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