Thomas v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 5/19/2017 for receipt of defendant's opposition brief, with plaintiff's reply brief due by 6/5/2017. Order signed by Magistrate Judge Erica P. Grosjean on 4/24/2017. (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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ERIC BRIAN THOMAS,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:16-CV-01044-EPG
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO FILE RESPONSE 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 three

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weeks from April 28, 2017, to May 19, 2017. This is Defendant’s first request for extension.

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Good cause exists as counsel for Defendant had to take unanticipated medical leave to care of

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her elderly mother and has had debilitating migraines, which necessitated additional time off.

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Because of the unanticipated leave, counsel for Defendant has not had sufficient time to respond

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to various pending matters that currently conflict with the current deadline of April 28, 2017 or

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adequately research and analyze the issues presented by Plaintiff. Defendant respectfully

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Joint Stipulation and Order re Extension of Time, Case No. 1:16-CV-01044-EPG

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requests additional time to respond to Plaintiff’s Motion for Summary Judgment. Defendant

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makes this 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: April 21, 2017

/s/ *Cyrsu Safa
(*as authorized by email on April 21, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: April 21, 2017

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

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By

/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

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Joint Stipulation and Order re Extension of Time, Case No. 1:16-CV-01044-EPG

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ORDER

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Based on the above stipulation and good cause appearing therein, the Court grants
Defendant an extension of time to file her opposition to Plaintiff’s opening brief. Defendant’s
opposition brief shall be filed no later than May 19, 2017. Plaintiff may file his reply brief no
later than June 5, 2017.
No further extensions of this deadline will be granted.
IT IS SO ORDERED.

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Dated:

April 24, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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Joint Stipulation and Order re Extension of Time, Case No. 1:16-CV-01044-EPG

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