Hunter v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER TO EXTEND TIME TO FILE OPENING BRIEF, signed by Magistrate Judge Jeremy D. Peterson on 5/18/2018. (Dunbar-Kari, K)

1
2
3
4
5

Denise Bourgeois Haley
Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
JILL ELIZABETH HUNTER

6
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16
17

JILL ELIZABETH HUNTER
Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

)
)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 1:17-cv-00952-JDP
STIPULATION TO EXTEND TIME TO
FILE OPENING BRIEF; ORDER
(SECOND REQUEST)

18
19

Plaintiff Jill Elizabeth Hunter and Defendant Nancy A. Berryhill, Acting Commissioner

20

of Social Security, through their undersigned attorneys, stipulated, subject to this court’s

21

approval, to extend the time by 30 days from April 11, 2018 to May 11, 2018 for Plaintiff to file

22

an Opening Brief, with all other dates in the Court’s Order Concerning Review of Social

23

Security Cases extended accordingly. This is Plaintiff's second request for an extension. This

24

request is made at the request of Plaintiff’s counsel to allow additional time to finish this motion.

25

Counsel has been working on this motion but was called out of town this weekend on a family

26
27
28

-1-

1

matter leaving before the motion was completed. Then when counsel returned to the office, the

2

ALJ required appeared in Medford, Oregan. Counsel is leaving shortly for a flight and is unable

3

to attend to this matter timely. Counsel is working diligently but she was not able to complete

4

this timely. Counsel departure is unexpected and counsel is working zealously to complete this

5

matter. Counsel respectfully requests one-week extension as she will not return until Wednesday

6

and has another out of town hearing on Friday. Counsel will do all she can to file this by Monday

7

May 21, 2018. Counsel respectfully makes this request in good faith and for good cause.

8

DATE: May 14, 2018

Respectfully submitted,
LAWRENCE D. ROHLFING

9

/s/ Denise Bourgeois Haley
BY: _______________________
Denise Bourgeois Haley

10
11

Attorney for plaintiff Ms. Jill Elizabeth Hunter

12
13
14
15
16

DATE: May 14, 2018

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

17
18
19
20
21

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

22
23
24
25
26
27
28

-2-

ORDER

1
2

For the reasons provided in the Parties’ stipulation, the Court finds good cause to grant

3

Plaintiff additional time up to and including May 21, 2018, to file the opening brief. All other

4

remaining deadlines in the scheduling order are modified accordingly.

5
IT IS SO ORDERED.

6
7
8

Dated:

May 18, 2018

/s/

UNITED STATES MAGISTRATE JUDGE

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Jeremy D. Peterson

-3-