Rodriguez v. Commissioner of Social Security

Filing 13

STIPULATION AND ORDER TO EXTEND TIME TO FILE OPENING BRIEF signed by Magistrate Judge Gary S. Austin on 3/17/2017: Pursuant to the parties' stipulation (Doc. 12 ), Plaintiff's request for an extension of time to file the opening brief is granted nunc pro tunc. Plaintiff shall file her opening brief no later than April 12, 2017. All other dates in the scheduling order issued on July 29, 2016 (Doc. 3 ) are modified accordingly. (Valdez, E)

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Denise Bourgeois Haley

Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
STACEY LYNN RODRIGUEZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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STACEY LYNN RODRIGUEZ

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Plaintiff,
v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 1:16-cv-01106-GSA
STIPULATION AND ORDER TO
EXTEND TIME TO FILE OPENING
BRIEF
(FIRST REQUEST)

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Plaintiff Stacey Lynn Rodriguez and Defendant Carolyn W. Colvin, Acting
Commissioner of Social Security, through their undersigned attorneys, stipulate,
subject to this court’s approval, to extend the time by 30 days from March 13,
2017 to April 12, 2017 for Plaintiff to file a Opening Brief, with all other dates in
the Court’s Order Concerning Review Of Social Security Cases extended
accordingly. This is Plaintiff's first request for continuance. This request is made at
the request of Plaintiff’s counsel to allow additional time to fully research the
issues presented. Counsel has not been able to complete the motion timely due to
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her case load expansion since one of the attorneys in our office left and is yet to be

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replaced. Counsel mistakenly failed to properly calendar this matter as well and

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became aware of the error today. Counsel needs additional time to properly

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address the issues in this case. Counsel has sought this continuance immediately

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and in good faith.

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DATE: March 14, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley
BY: _______________________
Denise Bourgeois Haley

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Attorney for plaintiff Ms. Stacey Lynn Rodriguez

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DATE: March 14, 2017

PHILLIP A.TALBET
United States Attorney

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/s/ Ben A. Porter
BY: ____________________________
Ben A. Porter
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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ORDER

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Pursuant to the parties’ stipulation (Doc. 12), Plaintiff’s request for an

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extension of time to file the opening brief is granted nunc pro tunc. Plaintiff shall

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file her opening brief no later than April 12, 2017. All other dates in the

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scheduling order issued on July 29, 2016 (Doc. 3) are modified accordingly.

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IT IS SO ORDERED.
Dated:

March 17, 2017

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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