Lopez v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER for an Extension of Time (First Request), signed by Magistrate Judge Barbara A. McAuliffe on 7/18/2018. Pursuant to the parties' stipulation, and good cause appearing, IT IS HEREBY ORDERED that Defendant shall have an extension of time to August 17, 2018, to file a response brief, and Plaintiff shall have an extension of time to September 21, 2018, to file a reply brief. (Valdez, E)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHEA LITA BOND, SBN D.C. 469103
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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FRESNO DIVISION
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ALMA LOPEZ,
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Plaintiff,
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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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) Case No. 1:17-cv-01501-BAM
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME (FIRST REQUEST)
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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 to file her Responsive Brief be extended from July 19,
2018, to August 17, 2018, and Plaintiff’s time for filing a Reply Brief be extended to September
21, 2018. This is the parties’ first request for an extension of time in this matter.

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Defendant respectfully requests additional time to file her Responsive Brief because the
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Of Counsel for Defendant is a fairly recent hire who just received this case assignment and needs
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sufficient time to review the record, to evaluate the issues raised in Plaintiff’s motion, and to
prepare Defendant’s response to the motion.

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Stip. & Order for Ext.; No. 1:17-cv-01501-BAM

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Plaintiff respectfully requests additional time to file her Reply Brief because her counsel
will be on maternity leave through mid-September and needs sufficient time to prepare the brief
upon return.
The parties’ request is made in good faith and with no intention to unduly delay the
proceedings, and counsel apologizes for any inconvenience.
It is therefore respectfully requested that Defendant be granted an extension of time to
file her Responsive Brief, through and including August 17, 2018, and that Plaintiff be granted
an extension of time to file her Reply Brief, through and including September 21, 2018.

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Respectfully submitted,

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Dated: July 17, 2018

/s/ Michelle Shvarts
(*as authorized via email on July 17, 2018)
MICHELLE SHVARTS
Attorney for Plaintiff

Dated: July 17, 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/ Shea Lita Bond
SHEA LITA BOND
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 good cause appearing, IT IS HEREBY

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ORDERED that Defendant shall have an extension of time to August 17, 2018, to file a response

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brief, and Plaintiff shall have an extension of time to September 21, 2018, to file a reply brief.
IT IS SO ORDERED.

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Dated:

/s/ Barbara

July 18, 2018

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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Stip. & Order for Ext.; No. 1:17-cv-01501-BAM

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