McMillen v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER for a Second Extension of Time for Defendant's Response to Plaintiff's Opening Brief. 20 . Defendant has until May 18, 2018, to submit a response to Plaintiff's Opening Brief. All other dates in the Scheduling Order (Doc. 6) shall be extended accordingly. Order signed by Magistrate Judge Sheila K. Oberto on 5/3/2018. (Timken, A)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
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

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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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FRED D. MCMILLEN IV,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:17-cv-00664-SKO
STIPULATION AND ORDER FOR A
SECOND EXTENSION OF TIME FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S OPENING BRIEF
(Doc. 20)

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time of 14 additional days to

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respond to Plaintiff’s opening brief. The current due date is May 4, 2018. The new due date will

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be May 18, 2018.

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There is good cause for this request. Since the granting of Defendant’s previous request

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for a 35-day extension of time, Defendant’s counsel had been diligently addressing her full

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workload. In addition, during the weekend of March 30, 2018, Defendant’s counsel had a

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serious personal emergency and took multiple days of leave to address and recover from the

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emergency and continues to take leave intermittently for treatment. Defendant’s counsel is

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continuing to address and prioritize the backlog of cases that she could not address while on

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leave.

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Thus, Defendant is respectfully requesting additional time up to and including May 18,

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2018, to fully review the record and research the issues presented by Plaintiff’s opening brief in

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this case. This request is made in good faith with no intention to unduly delay the proceedings.

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Respectfully submitted,
Date: May 3, 2018

FORSLUND LAW LLC

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s/ Jacqueline A. Forslund by C.Chen*
(As authorized by email on 5/3/2018)
JACQUELINE A. FORSLUND
Attorneys for Plaintiff

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Date: May 3, 2018

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MCGREGOR W. SCOTT
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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Pursuant to the parties’ above second “Stipulation for Extension of Time” for Defendant

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to file the response to Plaintiff’s Opening Brief (Doc. 20), IT IS HEREBY ORDERED that

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Defendant has until May 18, 2018, to submit a response to Plaintiff’s Opening Brief. All other

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dates in the Scheduling Order (Doc. 6) shall be extended accordingly.

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IT IS SO ORDERED.

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Dated:

May 3, 2018

/s/

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

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