Roque v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER to EXTEND TIME to FILE PLAINTIFF'S OPENING BRIEF. Plaintiff shall file her Opening Brief on or before January 4, 2018. All other deadlines set forth in the Scheduling Order (Doc. 11) are modified accordingly. Order signed by Magistrate Judge Sheila K. Oberto on 12/8/2017. (Timken, A)

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Cyrus Safa
Attorney at Law: 282971
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
MICHELLE L. ROQUE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MICHELLE L. ROQUE
Plaintiff,

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v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 1:17-cv-00192-SKO
STIPULATION TO EXTEND TIME
TO FILE PLAINTIFF’S OPENING
BRIEF; ORDER
(SECOND REQUEST)
(Doc. 21)

Plaintiff Michelle L. Roque and Defendant Nancy A. Berryhill, Acting
Commissioner of Social Security, through their undersigned attorneys, stipulate,

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subject to this court’s approval, to extend the time by 28 days from December 7,

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2017 to January 4, 2018 for Plaintiff to file a Plaintiff’s Opening Brief, with all

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other dates in the Court’s Order Concerning Review of Social Security Cases

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extended accordingly. This is Plaintiff's second request for an extension, the first
being related to the settlement proposal.

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This request is made at the request of Plaintiff’s counsel to allow additional

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time to fully research the issues presented. Plaintiff’s counsel missed work for part

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of last week due to the flu. Plaintiff’s counsel subsequently attended an out-of-state

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hearing within the last week. As a result of counsel’s illness, counsel required

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extensions on briefing due last week, which bled into the current week. Counsel

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has had five dispositive motions due this week alone. Counsel attempted to get

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ahead of the briefing by working over the weekend, but will be unable to complete

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the briefing in this case by the end of the day.

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Counsel has met with members of his office today and begun the process of

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re-assigning several cases internally to help alleviate Counsel’s workload and

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avoid any further extensions. Counsel is aware of the Court’s heavy workload and

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sincerely apologizes for any inconvenience this request may have on the Court, its

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staff, and all parties involved.

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DATE: December 7, 2017

LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Michelle L. Roque

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Respectfully submitted,

DATE: December 7, 2017

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
Social Security Administration

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/s/ Margaret I. Branick-Abilla
BY: ____________________________
Margaret I. Branick-Abilla
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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ORDER

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Pursuant to the parties’ above stipulation showing good cause for a

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requested extension of time for Plaintiff to file her Opening Brief (Doc. 21), the

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request is hereby GRANTED.

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Plaintiff shall file her Opening Brief on or before January 4, 2018. All other
deadlines set forth in the Scheduling Order (Doc. 11) are modified accordingly.

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IT IS SO ORDERED.
Dated:

December 8, 2017

/s/

UNITED STATES MAGISTRATE JUDGE

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Sheila K. Oberto

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