Harrell v. Commissioner of Social Security

Filing 16

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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1 2 3 4 5 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 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 JULIE ANN HARRELL 12 Plaintiff, 13 v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security, 15 16 Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:17-cv-01503-GSA STIPULATION TO EXTEND TIME TO FILE OPENING BRIEF (FIRST REQUEST) 17 18 Plaintiff Julie Ann Harrell and Defendant Nancy A. Berryhill, Acting 19 Commissioner of Social Security, through their undersigned attorneys, stipulate, 20 subject to this court’s approval, to extend the time by 35 days from July 18, 2018 21 to August 22, 2018 for Plaintiff to file an Opening Brief, with all other dates in the 22 Court’s Order Concerning Review of Social Security Cases extended accordingly. 23 This is Plaintiff's first request for an extension. This request is made at the request 24 of Plaintiff’s counsel to allow additional time to fully research the issues presented. 25 Counsel’s mother has the first of three kidney surgeries scheduled on July 17, 26 27 28 -1- 1 2018. Counsel needs to take additional time to place all her mother’s personal and 2 financial matters in order. 3 This is not an ordinary circumstance for Counsel and Counsel sincerely 4 apologizes to the Court for any inconvenience this may have cause. Counsel’s firm 5 has hired another associate to help Counsel during this difficult time. 6 7 DATE: July 16, 2018 Respectfully submitted, LAWRENCE D. ROHLFING 8 /s/ Monica Perales BY: _______________________ Monica Perales 9 10 Attorney for plaintiff Ms. Julie Ann Harrell 11 12 13 DATE: July 16, 2018 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration 14 15 16 /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| 17 18 19 20 21 22 IT IS SO ORDERED. 23 Dated: 24 July 18, 2018 /s/ Gary S. Austin UNITED STATES MAGISTRATE JUDGE 25 26 27 28 -2- 1 2 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 3 4 5 6 7 8 9 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4-

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