Limones v. Commissioner of Social Security

Filing 18

First stipulation for extension of time and Order, signed by Magistrate Judge Erica P. Grosjean on 8/10/2018. (Filing Deadline: 8/27/2018) (Rosales, O)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ELIZABETH FIRER
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105-1545
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION

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EDWARD RALPH LIMONES,
Plaintiff,

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vs.

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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-01511-EPG
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) FIRST STIPULATION FOR EXTENSION
) OF TIME AND ORDER
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IT IS HEREBY STIPULATED, by and between Edward Ralph Limones (Plaintiff) and

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Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their

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respective counsel of record, that, with the Court’s approval, Defendant shall have an extension of

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time of fourteen (14) days to file her Opposition to Plaintiff’s Opening Brief. The current due date

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is August 13, 2018. The new date will be August 27, 2018. All other deadlines will extend

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accordingly.

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Defense counsel needs an extension of time because the attorney responsible for briefing
this case is a new hire who needs more time to draft the response and go through the necessary in1

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house reviews and her reviewer, due to her own heavy workload demands, needed more time to

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review counsel’s brief. This request is made in good faith with no intention to delay unduly the

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proceedings. Counsel apologizes to the Court and Plaintiff for any inconvenience this delay may

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cause.

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Respectfully submitted,

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Dated: August 10, 2018

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By: /s/ Elizabeth Firer
ELIZABETH FIRER
Special Assistant United States Attorney
Attorneys for Defendant

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OF COUNSEL FOR DEFENDANT
S. WYETH MCADAM
Assistant Regional Counsel
/s/ Cyrus Safa
CYRUS SAFA
Attorneys for Plaintiff
LAW OFFICES OF LAWRENCE D. ROHLFING
(*As authorized via e-mail on August 10, 2018)

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ORDER
Based on the above stipulation of the parties, and good cause appearing, Defendant shall

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file her Opposition to Plaintiff’s Opening Brief no later than August 27, 2018. All other deadlines

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in the Court’s Scheduling Order are extended accordingly.

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IT IS SO ORDERED.

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Dated:

August 10, 2018

/s/
UNITED STATES MAGISTRATE JUDGE

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