Zenaty Jr. v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER for an Extension of Time of 60 Days for Defendant's Response to Plaintiff's Opening Brief, signed by Magistrate Judge Barbara A. McAuliffe on 7/17/2018. Pursuant to the parties' stipulation, and for cause shown, I T IS HEREBY ORDERED that Defendant shall have an extension of time to September 18, 2018, in which to file a response to Plaintiff's opening brief. All other deadlines set forth in the Court's Scheduling Order shall be extended accordingly. (Valdez, E)

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

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Case No.: 1:17-cv-01362-BAM
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 60 DAYS FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S OPENING BRIEF

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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 60 additional days to

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respond to Plaintiff’s opening brief. The current due date is July 20, 2018. The new due date

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will be September 18, 2018.

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This is Defendant’s first request for an extension of time in this case. There is good

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cause for this request. Since the filing of Plaintiff’s opening brief, Defendant’s counsel has been

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diligently addressing her full workload of district court cases and other cases that could not be

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assigned to another attorney. Furthermore, Defendant’s counsel will be on approved leave for

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approximately four weeks from July to August.

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

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18, 2018, to fully review the record and research the issues presented by Plaintiff’s opening brief

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

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proceedings.

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Respectfully submitted,
Date: July 16, 2018

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s/ Shanny J. Lee by C.Chen*
(As authorized by email on 7/16/2018)
SHANNY J. LEE
Attorneys for Plaintiff

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LAW OFFICES OF HARRY J. BINDER AND
CHARLES E. BINDER, P.C.

Date: July 16, 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’ stipulation, and for cause shown, IT IS HEREBY ORDERED that
Defendant shall have an extension of time to September 18, 2018, in which to file a response to
Plaintiff’s opening brief. All other deadlines set forth in the Court’s Scheduling Order shall be
extended accordingly.
IT IS SO ORDERED.
Dated:

/s/ Barbara

July 17, 2018

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A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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