Castro v. Commissioner of Social Security
Filing
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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: (562)437-7006
Fax: (562)432-2935
E-Mail: rohlfing.office@rohlfinglaw.com
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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