Joliff v. Commissioner of Social Security

Filing 12

Joint STIPULATION and ORDER for Extension of Time: that Defendant shall have an extension of time, to and including June 12, 2017, in which to file an Opposition to Plaintiff's Opening Brief; and that all other deadlines set forth in the Case Management Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 4/21/2017. (Herman, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
ADAM LAZAR, CSBN 237485
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[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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DENZEL JOLIFF,
Plaintiff,

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

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Defendant.

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) Case No.: 1:16-cv-01058-BAM
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) JOINT STIPULATION AND ORDER FOR
) EXTENSION OF TIME
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to

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Plaintiff’s Opening Brief, originally due on April 13, 2017, by 60 days, through and including

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Tuesday, June 12, 2017. This is the Commissioner’s first request for an extension of time in this

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matter.
An extension of time is needed in order to prepare Defendant’s opposition because of the

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drafting attorney’s exceptionally heavy workload, in which the attorney must conduct pre-trial,

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participate in a multi-day hearing, and draft post-hearing briefs for a recently-scheduled

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arbitration, in addition to the attorney’s regular district court workload and drafting two Ninth

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Circuit briefs. This request is made in good faith with no intention to unduly delay the

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proceedings. Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this

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request, on April 12, 2017.

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Respectfully submitted this 12th day of April, 2017.

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PHILLIP A. TALBERT
United States Attorney
DEBORAH STACHEL
Regional Chief Counsel, Region IX

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By

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/s/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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Based upon the above stipulation of the parties, and for cause shown, IT IS HEREBY

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ORDERED that Defendant shall have an extension of time, to and including June 12, 2017, in

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which to file an Opposition to Plaintiff’s Opening Brief; and that all other deadlines set forth in

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the Case Management Order shall be extended accordingly.

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IT IS SO ORDERED.

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Dated:

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April 21, 2017

/s/ Barbara

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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