Turner v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER to Extend Time to File Appellant's Opening Brief signed by Magistrate Judge Gary S. Austin on 9/8/2017. (Sant Agata, S)

1
2
3
4
5

Denise Bourgeois Haley
Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
REGINAL MAE TURNER

6
7
8
UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

REGINAL MAE TURNER

12

Plaintiff,

13

v.

14

NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

15
16

Defendant.

)
)
)
)
)
)
)
)
)
)
)

Case No.: 1:17-cv-00022-GSA
STIPULATION TO EXTEND TIME
TO FILE APPELLANT’S OPENING
BRIEF
(FIRST REQUEST)

17
18
19

Plaintiff Reginal Mae Turner and Defendant Carolyn W. Colvin, Acting

20

Commissioner of Social Security, through their undersigned attorneys, stipulate,

21

subject to this court’s approval, to extend the time by 28 days from August 30,

22

2017 to October 30, 2017 for Plaintiff to file a Appellant’s Opening Brief, with all

23

other dates in the Court’s Order Concerning Review Of Social Security Cases

24

extended accordingly. This request is made at the request of Plaintiff’s counsel to

25

allow additional time to fully research the issues presented. Counsel currently has

26
27
28

-1-

1

11 motions overdue and is trying to complete all as soon as possible. Counsel’s

2

firm lost an attorney last June 2016. Counsel has hired four attorneys’ to handle

3

that attorney’s caseload consecutively and the last one left on Friday. This matter

4

had been reassigned to the attorney who left on Friday, September 1, 2017.

5

Counsel has been trying to do as many motions as possible but remains committed

6

to giving each case the time and focus required to present the best argument

7

possible on the client’s behalf. Counsel appreciates that courtesy and patience of

8

the defendant and this court and counsel assures the court that she continues to

9

zealously represent her clients as best possible under the circumstances. Counsel

10

requests this extension in good faith.

11

DATE: September 5, 2017

LAWRENCE D. ROHLFING

12

/s/ Denise Bourgeois Haley
BY: _______________________
Denise Bourgeois Haley

13
14

Attorney for plaintiff Reginal Mae Turner

15
16

Respectfully submitted,

DATE: September 5, 2017

17
18

PHILLIP A.TALBET
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
Social Security Administration

19
20
/s/ Sharon Lahey
BY: ____________________________
Sharon Lahey
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

21
22
23
24
25

///

26
27
28

-2-

1

///

2

///
ORDER

3
4

Pursuant to the stipulation of the parties (Doc. 13), Plaintiff’s Opening Brief
shall be filed no later than October 30, 2017. All other dates in the Scheduling

5

Order dated January 9, 2017 (Doc. 5) shall be modified accordingly.

6
7
8
9

IT IS SO ORDERED.
Dated:

September 8, 2017

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-3-