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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1 2 3 4 5 6 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 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 VICTORIA ANN CASTRO Plaintiff, 12 vs. 13 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 14 15 16 Defendant. ) ) ) ) ) ) ) ) ) ) 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 17 of Social Security, through their undersigned attorneys, stipulate, subject to this court’s approval, 18 to extend the time by 28 days from September 5, 2017 to October 5, 2017 for Plaintiff to file a 19 Opening Brief, with all other dates in the Court’s Order Concerning Review Of Social Security 20 Cases extended accordingly. This request is made at the request of Plaintiff’s counsel to allow 21 additional time to fully research the issues presented. Counsel currently has 11 motions overdue 22 and is trying to complete all as soon as possible. Counsel’s firm lost an attorney last June 2016. 23 Counsel has hired four attorneys’ to handle that attorney’s caseload consecutively and the last 24 one left on Friday. Counsel has been trying to do as many as possible but remains committed to 25 giving each case the time and focus required to present the best argument possible on the client’s 26 27 28 -1- 1 behalf. Counsel appreciates that courtesy and patience of the defendant and this court and 2 counsel assures the court that she continues to zealously represent her clients as best possible 3 under the circumstances. Counsel requests this extension in good faith. 4 DATE: September 5, 2017 Respectfully submitted, 5 LAWRENCE D. ROHLFING 6 /s/ Denise Bourgeois Haley 7 BY: _______________________ Denise Bourgeois Haley Attorney for plaintiff Ms. Victoria Ann Castro 8 9 DATE: September 5, 2017 10 PHILLIP A.TALBET United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration 11 12 /s/ Tina Naicker 13 BY: ____________________________ Tina Naicker Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill [*authorized by e-mail] 14 15 16 17 ORDER 18 Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY 19 ORDERED that Plaintiff shall have an extension of time, to and including October 5, 2017, in 20 21 22 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. 23 24 Dated: /s/ Barbara September 11, 2017 26 28 _ UNITED STATES MAGISTRATE JUDGE 25 27 A. McAuliffe -2-

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