Castro v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER to Extend Time to File Opening Brief: that Plaintiff shall have an extension of time, to and including October 5, 2017, in which to file Plaintiffs Opening Brief; and that all other deadlines set forth in the Case Management Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 9/11/2017. (Herman, H)

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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
VICTORIA ANN CASTRO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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VICTORIA ANN CASTRO
Plaintiff,

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vs.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 1:17-cv-00025-BAM
STIPULATION AND ORDER TO EXTEND
TIME TO FILE OPENING BRIEF
(FIRST REQUEST)

Plaintiff Victoria Ann Castro and Defendant Carolyn W. Colvin, Acting Commissioner

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of Social Security, through their undersigned attorneys, stipulate, subject to this court’s approval,

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to extend the time by 28 days from September 5, 2017 to October 5, 2017 for Plaintiff to file a

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Opening Brief, with all other dates in the Court’s Order Concerning Review Of Social Security

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

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additional time to fully research the issues presented. Counsel currently has 11 motions overdue

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and is trying to complete all as soon as possible. Counsel’s firm lost an attorney last June 2016.

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Counsel has hired four attorneys’ to handle that attorney’s caseload consecutively and the last

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one left on Friday. Counsel has been trying to do as many as possible but remains committed to

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giving each case the time and focus required to present the best argument possible on the client’s

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behalf. Counsel appreciates that courtesy and patience of the defendant and this court and

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counsel assures the court that she continues to zealously represent her clients as best possible

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under the circumstances. Counsel requests this extension in good faith.

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DATE: September 5, 2017

Respectfully submitted,

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LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley

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BY: _______________________
Denise Bourgeois Haley
Attorney for plaintiff Ms. Victoria Ann Castro

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DATE: September 5, 2017

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PHILLIP A.TALBET

United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
Social Security Administration

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/s/ Tina Naicker

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BY: ____________________________
Tina Naicker
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
[*authorized by e-mail]

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ORDER

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Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY

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ORDERED that Plaintiff shall have an extension of time, to and including October 5, 2017, in

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which to file Plaintiff’s Opening Brief; and that all other deadlines set forth in the Case
Management Order shall be extended accordingly.

IT IS SO ORDERED.

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Dated:

/s/ Barbara

September 11, 2017

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_

UNITED STATES MAGISTRATE JUDGE

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A. McAuliffe

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