Raquenio v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER to Extend Time to File Plaintiff's Opening Brief, signed by Magistrate Judge Barbara A. McAuliffe on 8/23/17. (Gonzalez, R)

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1 2 3 4 5 6 Cyrus Safa Attorney at Law: 282971 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)437-7006 Fax: (562)432-2935 E-Mail: rohlfing.office@rohlfinglaw.com Attorneys for Plaintiff CONNIE MALIA RAQUENIO 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 CONNIE MALIA RAQUENIO Plaintiff, 13 v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 15 16 17 Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:16-cv-01830-BAM STIPULATION AND ORDER TO EXTEND TIME TO FILE PLAINTIFF’S OPENING BRIEF (SECOND REQUEST) 18 19 Plaintiff Connie Malia Raquenio and Nancy A. Berryhill, Acting 20 Commissioner of Social Security, through their undersigned attorneys, stipulate, 21 subject to this court’s approval, to extend the time by 3 days from August 22, 2017 22 to August 25, 2017 for Plaintiff to file Plaintiff’s Opening Brief, with all other 23 dates in the Court’s Order Concerning Review Of Social Security Cases extended 24 accordingly. This is Plaintiff's second request for an extension. This request is 25 made at the request of Plaintiff’s counsel who, due to unforeseen circumstances, 26 covered two out-of-town hearings this week for another attorney from counsel’s 27 28 -1- 1 firm on very short notice. As a result, counsel will need additional time to fully 2 research the issues presented. 3 DATE: August 22, 2017 Respectfully submitted, LAWRENCE D. ROHLFING 4 /s/ Cyrus Safa 5 BY: _______________________ Cyrus Safa Attorney for plaintiff Ms. Connie Malia Raquenio 6 7 8 DATE: August 22, 2017 PHILLIP A.TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration /s/ Sundeep Patel 9 10 11 12 BY: ____________________________ Sundeep Patel Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 13 14 15 ORDER 16 17 18 19 Pursuant to the stipulation of the parties, and for good cause appearing, IT IS HEREBY ORDERED that Plaintiff shall have an extension of time to August 25, 2017, in which to file Plaintiff’s opening brief. All other deadlines set forth in the Court’s Scheduling Order shall be 20 modified accordingly. 21 IT IS SO ORDERED. 22 23 Dated: /s/ Barbara August 23, 2017 25 26 28 _ UNITED STATES MAGISTRATE JUDGE 24 27 A. McAuliffe -2-

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