Bradley v. Commissioner of Social Security

Filing 17

JOINT STIPULATION AND ORDER FOR AN EXTENSION OF TIME, signed by Magistrate Judge Gary S. Austin on 7/31/2018. (Kusamura, W)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
BEATRICE NA, CSBN 303390
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 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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) Case No. 1:17-cv-01322-GSA
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) JOINT STIPULATION AND ORDER FOR
) AN EXTENSION OF TIME
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REBECCA BRADLEY,
Plaintiff,

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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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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’s time for responding to Plaintiff’s Opening Brief be extended

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from July 30, 2018 to August 29, 2018. This is Defendant’s first request for an extension of time

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to respond to Plaintiff’s Opening Brief.

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Defendant requests this extension due to her counsel’s heavy workload for the months of

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July and August 2018. Defendant’s counsel is currently responsible for an appellate brief in the

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United States Court of Appeals for the Ninth Circuit and seven briefs that are due for filing by

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August 16, 2018 in the United States District Court for the Districts of Eastern and Northern

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California. Defendant’s counsel respectfully requests this additional time to expend the

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necessary time to review the record and to evaluate the issues Plaintiff raised, and to submit

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Defendant’s response for review by this Court.

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The parties further stipulate that all subsequent deadlines set forth in the Court’s
Scheduling Order shall be extended accordingly.
The parties stipulate in good faith, with no intent to prolong proceedings unduly.

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Respectfully submitted,

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Dated: July 27, 2018

/s/ Beatrice Na for Lawrence D. Rohlfing*
(* As authorized by Enedina Perez via email on
July 27, 2018)
LAWRENCE D. ROHLFING

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Attorney for Plaintiff

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Dated: July 26, 2018

MCGREGOR W. SCOTT
United States Attorney

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By:

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/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney
Attorneys for Defendant

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IT IS SO ORDERED.
Dated:

July 31, 2018

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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