McDougal v. Commissioner of Social Security

Filing 20

Joint stipulation for extension of time, signed by Magistrate Judge Erica P. Grosjean on 7/14/2017. (Answering Brief Deadline: 8/28/2017) (Rosales, O)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH L. STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
TIMOTHY R. BOLIN, CSBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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(FRESNO)

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DESIREE MCDOUGAL
for Walter Jason Inman (deceased),
Plaintiff,
v.
ACTING COMMISSIONER
OF SOCIAL SECURITY,

) No. 1:16-cv-00962-EPG
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) JOINT STIPULATION
) FOR EXTENSION OF TIME
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Defendant.

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The parties hereby stipulate, through their undersigned attorneys, that, subject to the

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Court’s approval, Defendant shall have an extension of time until August 28, 2017, in which to

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file her answering brief, with all subsequent deadlines set forth in the Court’s scheduling order

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also extended accordingly. Defendant requests this extension because the originally assigned

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OGC attorney took extended leave abruptly, necessitating the sudden transfer of her cases to

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other attorneys, on top of their regular caseloads.

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When cases are assigned initially at OGC, they are automatically linked to the task

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calendar by the action taken by our paralegals. That did not happen in this case because it was a

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reassignment. Although the undersigned OGC attorney was added as attorney of record in this

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case, he mistakenly neglected to calendar it with his regular caseload, which includes six district

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court briefs due in the coming two weeks alone. He therefore begs the Court’s indulgence for

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additional time to review the record, proceedings, and opening brief. The parties stipulate in

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good faith, with no intent to delay proceedings unduly.

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Respectfully submitted,

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Date: July 13, 2017

/s/ Melissa Newel
MELISSA NEWEL
Attorney for Plaintiff

Date: July 13, 2017

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

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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Based on the foregoing joint stipulation, and for cause shown, THE COURT ORDERS
that Defendant shall have until August 28, 2017, to file her answering brief, with all subsequent
deadlines set forth in the Court’s scheduling order also extended accordingly.
IT IS SO ORDERED.

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Dated:

July 14, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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