Soroka v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER for an Extension of Time of 30 Days for Defendant's Response to Plaintiff's Opening Brief, signed by Magistrate Judge Gary S. Austin on 8/28/2018. (Valdez, E)

1
2
3
4
5
6
7
8

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

FRESNO DIVISION

12
13
14
15
16
17

MARTIN SOROKA,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

18

)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 1:17-cv-01571-GSA
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME OF 30
DAYS FOR DEFENDANT’S RESPONSE TO
PLAINTIFF’S OPENING BRIEF

19
20

IT IS HEREBY STIPULATED, by and between the parties, through their respective

21

counsel of record, that Defendant shall have an extension of time of 30 additional days to

22

respond to Plaintiff’s opening brief. The current due date is August 27, 2018. The new due date

23

will be September 26, 2018.

24

This is Defendant’s first request for an extension of time in this case and the first request

25

for an extension in this case overall. There is good cause for this request. Since the filing of

26

Plaintiff’s opening brief, Defendant’s counsel was on leave and had planned to address her full

27

workload of district court cases and other cases, including this case, upon her return. However,

28

an unanticipated matter in another district court case that required immediate attention upon

1

1

Defendant’s counsel’s return prevented Defendant’s counsel from completing Defendant’s

2

responsive brief in this case by the original due date.

3

Thus, Defendant is respectfully requesting additional time up to and including September

4

26, 2018, to fully review the record and research the issues presented by Plaintiff’s opening brief

5

in this case. This request is made in good faith with no intention to unduly delay the

6

proceedings.

7
8
9

Respectfully submitted,
Date: August 27, 2018

LAW OFFICES OF LAWRENCE D. ROHLFING

10
s/ Lawrence Rohlfing by C.Chen*
(As authorized by email on 8/27/2018)
CYRUS SAFA
Attorneys for Plaintiff

11
12
13
14

Date: August 27, 2018

15

MCGREGOR W. SCOTT
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

16
17

Attorneys for Defendant

18
19
20

IT IS SO ORDERED.

21
Dated:
22

August 28, 2018

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

23
24
25
26
27
28

2