Stoltzner v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER GRANTING the parties' stipulation for an extension of ten days for defendant to respond to plaintiff's opening brief, with the scheduling order modified accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 10/4/2017. (Rooney, M)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CAROLYN B. CHEN, CSBN 256628 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Carolyn.Chen@ssa.gov Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 FRESNO DIVISION 12 13 14 15 16 17 18 ANDY D. STOLTZNER, Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:16-cv-01490-EPG STIPULATION AND ORDER FOR AN EXTENSION OF TIME OF 10 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S OPENING BRIEF 19 20 IT IS HEREBY STIPULATED, by and between the parties, through their respective 21 counsel of record, that Defendant shall have an extension of time of an additional 10 days to 22 respond to Plaintiff’s opening brief. This is the first continuance sought by Defendant. The 23 current due date is October 3, 2017. The new due date will be October 13, 2017. 24 There is good cause for this request. Since the filing of Plaintiff’s opening brief, 25 Defendant’s counsel has been diligently addressing her full workload including several district 26 court cases and one Equal Employment Opportunity Commission matter involving discovery and 27 travel for depositions. Moreover, Defendant’s counsel was recently ordered on October 2, 2017, 28 to appear for a hearing on October 10, 2017. Therefore, Defendant is respectfully requesting 1 1 additional time up to and including October 13, 2017, to fully review the record and research the 2 issues presented by Plaintiff’s opening brief in this case. This request is made in good faith with 3 no intention to unduly delay the proceedings. 4 5 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 6 7 8 Respectfully submitted, Date: October 3, 2017 LAW OFFICES OF LAWRENCE D. ROHLFING 9 s/ Steven G. Rosales by C.Chen* (As authorized by e-mail on 10/3/2017) STEVEN G. ROSALES Attorneys for Plaintiff 10 11 12 13 14 15 16 17 Date: October 3, 2017 PHILLIP A. TALBERT United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney Attorneys for Defendant 18 19 20 21 22 23 24 25 26 27 28 2 1 2 ORDER For the reasons provided in the parties’ stipulation, an extension of time of an additional 3 10 days to respond to Plaintiff’s opening brief is GRANTED. The Court’s Scheduling Order is 4 modified accordingly. 5 6 7 IT IS SO ORDERED. Dated: October 4, 2017 /s/ 8 UNITED STATES MAGISTRATE JUDGE 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3

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