Harrell v. Commissioner of Social Security
Filing
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STIPULATION and ORDER to Extend Time to File Opening Brief signed by Magistrate Judge Gary S. Austin on 07/18/2018. (Flores, E)
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Monica Perales
Attorney at Law: 297739
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: (562)437-7006
Fax: (562)432-2935
E-Mail: rohlfing.office@rohlfinglaw.com
Attorneys for Plaintiff
JULIE ANN HARRELL
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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JULIE ANN HARRELL
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Plaintiff,
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v.
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NANCY A. BERRYHILL,
Acting Commissioner of Social
Security,
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Defendant.
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Case No.: 1:17-cv-01503-GSA
STIPULATION TO EXTEND TIME
TO FILE OPENING BRIEF
(FIRST REQUEST)
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Plaintiff Julie Ann Harrell and Defendant Nancy A. Berryhill, Acting
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Commissioner of Social Security, through their undersigned attorneys, stipulate,
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subject to this court’s approval, to extend the time by 35 days from July 18, 2018
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to August 22, 2018 for Plaintiff to file an Opening Brief, with all other dates in the
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Court’s Order Concerning Review of Social Security Cases extended accordingly.
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This is Plaintiff's first request for an extension. This request is made at the request
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of Plaintiff’s counsel to allow additional time to fully research the issues presented.
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Counsel’s mother has the first of three kidney surgeries scheduled on July 17,
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2018. Counsel needs to take additional time to place all her mother’s personal and
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financial matters in order.
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This is not an ordinary circumstance for Counsel and Counsel sincerely
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apologizes to the Court for any inconvenience this may have cause. Counsel’s firm
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has hired another associate to help Counsel during this difficult time.
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DATE: July 16, 2018
Respectfully submitted,
LAWRENCE D. ROHLFING
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/s/ Monica Perales
BY: _______________________
Monica Perales
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Attorney for plaintiff Ms. Julie Ann Harrell
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DATE: July 16, 2018
MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
Social Security Administration
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/s/ Asim Modi
BY: ____________________________
Asim Modi
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
Acting Commissioner of Social Security
|*authorized by e-mail|
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IT IS SO ORDERED.
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Dated:
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July 18, 2018
/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE
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CERTIFICATE OF SERVICE
FOR CASE NUMBER 1:17-CV-01503-GSA
I hereby certify that I electronically filed the foregoing with the Clerk of the
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Court for this court by using the CM/ECF system on July 17, 2018.
I certify that all participants in the case are registered CM/ECF users and
that service will be accomplished by the CM/ECF system.
/s/ Monica Perales
_______________________________
Monica Perales
Attorneys for Plaintiff
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