Brooks v. Commissioner of Social Security

Filing 18

Joint STIPULATION and ORDER for Extension of Time for Defendant to Respond to Plaintiff's Brief, signed by Magistrate Judge Barbara A. McAuliffe on 9/13/2018. Pursuant to the parties' stipulation, and good cause appearing, IT IS HEREBY ORDERED that Defendant shall have an extension of time to October 17, 2018, in which to file a response to Plaintiff's Opening Brief. All other deadlines set forth in the Court's Scheduling Order are 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
TINA L. NAICKER, CSBN 252766
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

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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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DIANE D. BROOKS,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:17-cv-01506-BAM
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S OPENING BRIEF.

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Opening Brief be extended from September 12, 2018 to

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October 17, 2018. This is Defendant’s first request for extension. Good cause exists to grant

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Defendant’s request for extension. Counsel has had three deaths in her family since June and

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was out on intermittent bereavement and medical leave for a family medical emergency that

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required hospital admission and surgery. Counsel was also out of the office on September 7th

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and 8th, 2018. Counsel has over 75+ active social security matters, of which require two or more

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dispositive motions a week until mid October. In addition, Counsel has a Ninth Circuit matter

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that is due in early October. As a result of Counsel’s leave and heavy workload, Defendant

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needs additional time to adequately review the transcript and properly respond to Plaintiff’s
JS for Extension of Time and PO, Case No. 1:17-cv-01506-BAM

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Motion for Remand. Defendant makes this request in good faith with no intention to unduly

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delay the proceedings. Counsel apologizes for the belated request, but did not anticipate taking

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additional leave from the several family deaths and family medical emergency. The parties

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further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: September 12, 2018

/s/ *Larry Rohlfing
(*as authorized by email on September 12, 2018)
LARRY ROHLFING
Attorney for Plaintiff

Dated: September 12, 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/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

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 October 17, 2018, in which to file

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a response to Plaintiff’s Opening Brief. All other deadlines set forth in the Court’s Scheduling

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Order are extended accordingly.
IT IS SO ORDERED.

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Dated:

/s/ Barbara

September 13, 2018

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time and PO, Case No. 1:17-cv-01506-BAM

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