Feese v. Commissioner of Social Security

Filing 12

STIPULATION and ORDER for Extension of Time to File Opposition to Motion for Summary Judgment, signed by Magistrate Judge Gary S. Austin on 9/11/2017. Opposition due by 11/1/2017. (Jessen, A)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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JOHN FEESE,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL
Acting Commissioner of Social Security,

) Case No.: 1:17-cv-00054-GSA
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) JOINT STUPULATION AND ORDER
) FOR EXTENSION OF TIME
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Defendant.

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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to

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Plaintiff’s Motion for Summary Judgment, originally due on September 27, 2017, by 35 days,

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through and including Wednesday, November 1, 2017. This is the Commissioner’s first request

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for an extension of time in this matter.

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An extension of time is needed in order to prepare Defendant’s opposition because

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counsel will be on his honeymoon for the last three weeks of September and the beginning of

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October, and faces a heavy caseload when he returns. This request is made in good faith with no

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intention to unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel,
who had no objection to this request, on September 8, 2017.
Stipulation for Extension of Time; 1:17-cv-00054-GSA 1

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Respectfully submitted,
Dated: September 8, 2017

PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney

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Attorneys for Defendant

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/s/ Jeffrey Duarte*
JEFFREY DUARTE
(*by email authorization)

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Attorney for Plaintiff

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Dated: September 8, 2017

By:

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ORDER

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Pursuant to the parties’ stipulation (Doc. 14), Defendant’s Opposition shall be filed no
later than November 1, 2017. Any Reply shall be filed no later than fifteen (15) days after the
filing of the Opposition.
IT IS SO ORDERED.

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Dated:

September 11, 2017

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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Stipulation for Extension of Time; 1:17-cv-00054-GSA 2