Farnsworth v. Commissioner of Social Security

Filing 18

JOINT STIPULATION and ORDER for Extension of Time: that Defendant shall have a thirty-one day extension of time, to and including February 19, 2018, in which to file a response Plaintiff's Motion for Summary Judgment; and that all other deadlines set forth in the Courts Scheduling Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 1/16/2018. (Herman, H)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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MICHELLE FARNSWORTH,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL
Acting Commissioner of Social Security,
Defendant.

) Case No.: 1:17-CV-00653-BAM
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) JOINT STIPULATION AND ORDER FOR
) EXTENSION OF TIME
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to

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Plaintiff’s Motion for Summary Judgment, originally due on January 19, 2018 by 31 days,

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through and including Monday, February 19, 2018. This is the Commissioner’s first request for

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an extension of time in this matter.

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An extension of time is needed in order to prepare Defendant’s opposition because the

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briefing attorney is leaving the agency and a new attorney has been assigned, who will require

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Stipulation for Extension of Time; 1:17-cv-00653-BAM 1

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sufficient time to familiarize and brief this matter. This request is made in good faith with no

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intention to unduly delay the proceedings.

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Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this request,
on January 10, 2018.

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Respectfully submitted,
Dated: January 10, 2018

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

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By:

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/s/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney

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Attorneys for Defendant

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Dated: January 10, 2018

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By:

/s/ Stewart Barasch*
STEWART BARASCH
(*by email authorization)
Attorney for Plaintiff

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ORDER

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Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY
ORDERED, that Defendant shall have a thirty-one day extension of time, to and including

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February 19, 2018, in which to file a response Plaintiff’s Motion for Summary Judgment; and

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that all other deadlines set forth in the Court’s Scheduling Order shall be extended accordingly.

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IT IS SO ORDERED.
Dated:

January 16, 2018

/s/ Barbara

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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Stipulation for Extension of Time; 1:17-cv-00653-BAM 2

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Stipulation for Extension of Time; 1:17-cv-00653-BAM 3