Ramirez v. Commissioner of Social Security

Filing 19

ORDER Re Unopposed Motion for First Extension of Time, signed by Magistrate Judge Gary S. Austin on 11/8/2017. Pursuant to the parties' stipulation (Doc. 18 ), Defendant shall file her Opposition to Plaintiff's Opening Brief on or before December 26, 2017. Plaintiff shall file any optional Reply within fifteen (15) days of the filing of the Opposition. (Valdez, E)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
GINA TOMASELLI, CSBM 267090
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - FRESNO

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VANESSA RAMIREZ,

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Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social
Security,
Defendant.

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) Case No. 1:17-cv-00126-GSA
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) UNOPPOSED MOTION FOR FIRST
) EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between Vanessa Ramirez (Plaintiff) and
Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and
through their respective counsel of record, that Defendant shall have an extension of
time of forty-five (45) days to file her Opposition to Plaintiff’s Opening Brief. The
current due date is November 9, 2017. The new date will be December 26, 2017. An
extension of time is needed because the attorney responsible for briefing is still working
through a backlog of cases due to having been out on medical leave and many of her

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cases due in November and December have already been extended. The office is
extremely busy at this time, particularly with the approaching holidays, such that her
cases cannot be transferred. This request is made in good faith with no intention to
unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly, such that Plaintiff’s reply brief shall be due January 10, 2018.

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Respectfully submitted,

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Date: November 6, 2017

LAWRENCE D. ROHLFING
By: /s/ Lawrence D. Rohlfing *
Law Offices of Lawrence D. Rohlfing
Attorney for Plaintiff
(*As authorized by e-mail on November 6, 2017)

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Date: November 6, 2017

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/s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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PHILLIP A. TALBERT
United States Attorney

Attorneys for Defendant
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ORDER
Pursuant to the parties’ stipulation (Doc. 18), Defendant shall file her Opposition

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to Plaintiff’s Opening Brief on or before December 26, 2017. Plaintiff shall file any

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optional Reply within fifteen (15) days of the filing of the Opposition.

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IT IS SO ORDERED.
Dated:

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November 8, 2017

JUDGE

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/s/ Gary S. Austin
UNITED STATES MAGISTRATE

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