Stoltzner v. Commissioner of Social Security
Filing
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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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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
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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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ANDY D. STOLTZNER,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.
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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
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IT IS HEREBY STIPULATED, by and between the parties, through their respective
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counsel of record, that Defendant shall have an extension of time of an additional 10 days to
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respond to Plaintiff’s opening brief. This is the first continuance sought by Defendant. The
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current due date is October 3, 2017. The new due date will be October 13, 2017.
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There is good cause for this request. Since the filing of Plaintiff’s opening brief,
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Defendant’s counsel has been diligently addressing her full workload including several district
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court cases and one Equal Employment Opportunity Commission matter involving discovery and
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travel for depositions. Moreover, Defendant’s counsel was recently ordered on October 2, 2017,
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to appear for a hearing on October 10, 2017. Therefore, Defendant is respectfully requesting
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additional time up to and including October 13, 2017, to fully review the record and research the
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issues presented by Plaintiff’s opening brief in this case. This request is made in good faith with
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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,
Date: October 3, 2017
LAW OFFICES OF LAWRENCE D. ROHLFING
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s/ Steven G. Rosales by C.Chen*
(As authorized by e-mail on 10/3/2017)
STEVEN G. ROSALES
Attorneys for Plaintiff
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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
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ORDER
For the reasons provided in the parties’ stipulation, an extension of time of an additional
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10 days to respond to Plaintiff’s opening brief is GRANTED. The Court’s Scheduling Order is
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modified accordingly.
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IT IS SO ORDERED.
Dated:
October 4, 2017
/s/
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UNITED STATES MAGISTRATE JUDGE
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