Schaefers v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 4/9/2018 for defendant to file its responsive brief, with all other scheduling dates set forth in the Court's Case Management Order extended accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 3/26/2018. (Rooney, M)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI, NYSBN 4692018
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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FRESNO DIVISION
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STACEY LYN SCHAEFERS,

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Plaintiff,

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v.

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NANCY A. BERRYHILL,
Deputy Commissioner for Operations,
performing the duties and functions not
reserved to the Commissioner of Social
Security,

) Case No.: 1:17-cv-00648-EPG
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) STIPULATION AND ORDER TO
) EXTEND BRIEFING SCHEDULE
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Defendant.

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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to
extend Defendant’s time to file her responsive brief with the Court by 10 days to April 9, 2018,
and that all other scheduling dates set forth in the Court’s Case Management Order shall be
extended accordingly. This is Defendant’s first request for an extension of time in this matter
and she requests it in good faith and without any intent to prolong proceedings unduly.
There is good cause for this extension request because counsel for Defendant has had
leave and workload issues that preclude filing her responsive brief by March 29, 2018. In

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particular, counsel for Defendant was on leave from March 15 through March 23, 2018, and is

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presently unable to fully review the record and prepare the Commissioner’s responsive brief

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before the March 29, 2018, deadline. Furthermore, counsel for Defendant has other pending

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workload issues that preclude filing the Commissioner’s responsive brief by the presently

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scheduled deadline, such as drafting briefs and summary judgment motions and negotiating (or

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litigating) attorney fee matters pursuant to the Equal Access to Justice Act before the district

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courts within the Ninth Circuit, finalizing discovery and preparing substantive pleadings in

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personnel-related litigation pending before the Equal Employment Opportunity Commission

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(EEOC), and preparing for an arbitration proceeding involving the agency and one of the

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agency’s collective bargaining units.
Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused
by this delay.

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Respectfully submitted,

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Date: March 26, 2018

LAW OFFICES OF LAWRENCE D.
ROHLFING

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By:
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/s/ Asim H. Modi for Monica Perales*
MONICA PERALES
*Authorized by email on March 26, 2018
Attorneys for Plaintiff

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Date: March 26, 2018

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Pursuant to the parties’ stipulation, Defendant’s time to file its responsive brief with the
Court is EXTENDED by 10 days to April 9, 2018, and all other scheduling dates set forth in the

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Court’s Case Management Order are EXTENDED accordingly.

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IT IS SO ORDERED.

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Dated:

March 26, 2018

/s/
UNITED STATES MAGISTRATE JUDGE

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