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)

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: [phone]
Fax: [phone]
E-Mail: [e-mail]
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-