Mardikian v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER for Extension of Time by Defendant to File her Responsive Brief (Defendant's First Request) signed by Magistrate Judge Gary S. Austin on 11/13/2017. Pursuant to the parties' stipulation (Doc. 15 ), Defendant shall file any Opposition no later than December 28, 2017. Plaintiff shall file any optional Reply within fifteen days of the filing of the Opposition. (Valdez, E)

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PHILIP TALBERT
United States Attorney
DEBORAH LEE STACHEL – CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
RICHARD M. RODRIGUEZ
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
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Plaintiff,
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vs.
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NANCY A. BERRYHILL, Acting Commissioner )
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of the Social Security Administration,
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Defendant.
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DAVID JOHN MARDIKIAN,

Case No: 1:17-cv-00181-GSA
STIPULATION FOR EXTENSION OF TIME
BY DEFENDANT TO FILE HER RESPONSIVE
BRIEF (DEFENDANT’S FIRST REQUEST)
AND ORDER

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The parties hereby stipulate through counsel and with the Court’s approval that

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Defendant’s time in which file and serve her responsive brief be extended from November 13,

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2017, up until and including December 28, 2017. This is the first extension sought by Defendant.

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There is good cause for this request. The undersigned needs to fly to Florida to attend to
his ailing mother who is in extremis and may not last through the weekend. In addition, I have
scheduled leave December 2, 2017, through December 9, 2017, making a shorter extension
problematic as I already have two briefs due the week of December 13, 2017. Plaintiff’s reply
would be due January 12, 2018.

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This request is made in good faith with no intention to unduly delay the proceedings.
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Stipulation and Order for Extension of Time

1:17-CV-00181-GSA

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Counsel for Defendant conferred with Plaintiff’s counsel by email on November 8, 2017,
who has no opposition to this request.
Respectfully submitted,

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Dated: November 8, 2017

PHILIP 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/Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant U.S. Attorney

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Attorneys for Defendant

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Dated: November 8, 2017

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/s/Jonathan O. Pena, Esq.
By: Richard M. Rodriguez,
as authorized by email on November 8, 2017
JONATHAN O. PENA, ESQ., CSBN: 278044
Attorney for Plaintiff

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ORDER

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Pursuant to the parties’ stipulation (Doc. 15), Defendant shall file any Opposition no later
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than December 28, 2017. Plaintiff shall file any optional Reply within fifteen days of the filing of the
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Opposition.
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IT IS SO ORDERED.

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Dated:

November 13, 2017

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Order for Extension of Time

1:17-CV-00181-GSA

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