Wright v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 1/5/2018 for the filing of defendant's opposition to plaintiff's opening brief. Order signed by Magistrate Judge Erica P. Grosjean on 12/5/2017. (Rooney, M)

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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KENDRA NICOLE WRIGHT,

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Plaintiff,

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vs.
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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-00271-EPG
SECOND STIPULATION FOR
EXTENSION OF TIME AND
ORDER THEREON

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IT IS HEREBY STIPULATED, by and between Kendra Nicole Wright (Plaintiff) and

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

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respective counsel of record, that, with the Court’s approval, Defendant shall have an extension of

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time of thirty (30) days to file her Opposition to Plaintiff’s Opening Brief. The current due date is

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December 6, 2017. The new date will be January 5, 2018. All other deadlines will extend

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accordingly.

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Defense counsel needs an extension of time because the attorney responsible for briefing

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this case is a new hire who received this case assignment after the initial extension. Counsel needs

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more time to draft the response and go through the necessary in-house reviews. This request is

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made in good faith with no intention to delay unduly the proceedings. Counsel apologizes to the

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Court for any inconvenience this delay may cause.

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This is Defendant’s second request for an extension.

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Respectfully submitted,

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Dated: December 4, 2017

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

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By: /s/ Elizabeth Firer
ELIZABETH FIRER
Special Assistant United States Attorney
Attorneys for Defendant

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/s/ S. Wyeth McAdam
S. WYETH MCADAM
Of Counsel for Defendant
Social Security Administration

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Dated: December 4, 2017

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/s/ Monica Perales
MONICA PERALES
Attorneys for Plaintiff
LAW OFFICES OF LAWRENCE D. ROHLFING
(*As authorized via e-mail on 12/4/17)

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ORDER
Good cause appearing, pursuant to the stipulation of the parties, Defendant shall file her
opposition to plaintiff’s opening brief on or before January 5, 2018.

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IT IS SO ORDERED.
Dated:

December 5, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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