Terrazas v. Commissioner of Social Security

Filing 19

Stipulation and Order for Extension of Time by Defendant to file her responsive brief (Defendants second request), signed by Magistrate Judge Erica P. Grosjean on 10/16/2017. (Responsive Brief due by 11/13/2017) (Rosales, O)

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1 2 3 4 5 6 7 8 PHILLIP TALBERT United States Attorney DEBORAH LEE STACHEL – CSBN 230138 Regional Chief Counsel, Region IX Social Security Administration RICHARD M. RODRIGUEZ Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8926 Facsimile: (415) 744-0134 E-Mail: Richard.Rodriguez@ssa.gov Attorneys for Defendant UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 FRESNO DIVISION 11 12 13 14 15 16 17 ) ) ) Plaintiff, ) ) vs. ) ) NANCY A. BERRYHILL, Acting Commissioner ) ) of the Social Security Administration, ) ) Defendant. ) ANNA MARIA TERRAZAS, Case No: 1:16-CV-01812-EPG STIPULATION AND ORDER FOR EXTENSION OF TIME BY DEFENDANT TO FILE HER RESPONSIVE BRIEF (DEFENDANT’S SECOND REQUEST) 18 The parties hereby stipulate through counsel and with the Court’s approval that 19 20 Defendant’s time in which file and serve her responsive brief be extended from October 13, 2017, 21 up to and including November 13, 2017. This is the first extension sought by Defendant. There is good cause for this request. I am in the process of requesting settlement authority 22 23 24 25 from my client and expect a response should be forthcoming within 15 days. Thereafter, I will need time to draft a stipulation and proposed order and discuss the terms of the stipulation with Plaintiff’s counsel. I anticipate the entire process will take no longer than 30 days. This request is made in good faith with no intention to unduly delay the proceedings. 26 \\\ 27 28 1 1 2 Counsel for Defendant conferred with Plaintiff’s counsel by email on October 13, 2017, who has no opposition to this request. Respectfully submitted, 3 4 Dated: October 13, 2017 PHILLIP TALBERT United States Attorney DEBORAH LEE STACHEL, Regional Chief Counsel, Region IX Social Security Administration 5 6 7 By: 8 /s/Richard M. Rodriguez RICHARD M. RODRIGUEZ Special Assistant U.S. Attorney 9 Attorneys for Defendant 10 11 12 13 14 Dated: October 13, 2017 /s/Denise Bourgeois Haley, Esq, CSBN: 143709 By: Richard M. Rodriguez, as authorized by email on October 13, 2017 DENISE BOURGEOIS HALEY, ESQ. Attorney for Plaintiff 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 ORDER 1 2 3 Pursuant to the parties’ stipulation, the time in which Defendant shall file and serve her responsive brief is extended from October 13, 2017, up to and including November 13, 2017. 4 IT IS SO ORDERED. 5 6 7 Dated: October 16, 2017 /s/ UNITED STATES MAGISTRATE JUDGE 8 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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