Ramirez v. Commissioner of Social Security

Filing 21

UNOPPOSED MOTION AND ORDER FOR SECOND EXTENSION OF TIME, signed by Magistrate Judge Gary S. Austin on 12/22/2017. (Kusamura, W)

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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,

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)
) Case No. 1:17-cv-00126-GSA
)
) UNOPPOSED MOTION AND ORDER
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) FOR SECOND EXTENSION OF TIME
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Defendant.
IT IS HEREBY STIPULATED, by and between Vanessa Ramirez (Plaintiff) and

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Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and

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through their respective counsel of record, that Defendant shall have an extension of

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time of thirty-day (30) days to file her Opposition to Plaintiff’s Opening Brief. The

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current due date is December 26, 2017. The new date will be January 25, 2018. An

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extension of time is needed because the attorney responsible for briefing this case has

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had to take some unexpected medical leave due to her ongoing health issue. With the

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approaching holidays, her case 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 February 9, 2018.

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Respectfully submitted,

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Date: December 21, 2017

LAWRENCE D. ROHLFING
By: /s/ Lawrence D. Rohlfing *
Law Offices of Lawrence D. Rohlfing
Attorney for Plaintiff
(*As authorized by e-mail on December 21, 2017)

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Date: December 21, 2017

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PHILLIP A. TALBERT
United States Attorney
/s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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Attorneys for Defendant

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ORDER

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Pursuant to stipulation the parties’ stipulation (Doc. 20), Defendant shall file her

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Opposition to Plaintiff’s Opening Brief on or before January 25, 2018. Any Reply

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shall be filed within fifteen (15) days of the filing of the Opposition.

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Dated : December 22, 2017

Gary S. Austin
United States Magistrate Judge

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