Ortiz v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER for an Extension of Time, signed by Magistrate Judge Barbara A. McAuliffe on 1/7/2019. Pursuant to the parties' stipulation, and good cause appearing, Defendant's time to file a response to Plaintiff's Opening Brief is extended to February 8, 2019. All other deadlines in the 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
BEATRICE NA, CSBN 303390
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Plaintiff,

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) Case No. 1:17-cv-01611-BAM
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) JOINT STIPULATION AND ORDER FOR
) AN EXTENSION OF TIME
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ALEXIS ORTIZ,

vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

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

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counsel of record, that Defendant’s time for responding to Plaintiff’s Opening Brief be extended

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from January 4, 2019 to February 8, 2019. This is Defendant’s first request for an extension of

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time to respond to Plaintiff’s Opening Brief.

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Defendant requests this extension due to her counsel’s heavy workload. Defendant’s

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counsel is currently responsible for two Social Security appellate cases before the United States

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Court of Appeals for the Ninth Circuit, in addition to ten cases that require imminent briefing in

Joint Stip. & Order for Ext.; 1:17-cv-01611-BAM

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the United States District Courts for the Eastern District, Northern District, and Southern District

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of California, and District of Nevada, as well as legal opinion assignments that advise

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components within the Social Security Administration in the administration of benefits under the

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Social Security Act.

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Defendant’s counsel respectfully requests this additional time to expend the necessary

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time to review the 1,327-page record and to evaluate the issues Plaintiff raised, and to submit

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Defendant’s response for review by this Court.

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The parties further stipulate that all subsequent deadlines set forth in the Court’s
Scheduling Order shall be extended accordingly.
The parties stipulate in good faith, with no intent to prolong proceedings unduly.

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Respectfully submitted,

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Dated: January 4, 2019

/s/ Beatrice Na for Cyrus Safa*
(* As authorized via email on January 2, 2019)
CYRUS SAFA

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Attorney for Plaintiff

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Dated: January 4, 2019

MCGREGOR W. SCOTT
United States Attorney

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By:

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Attorneys for Defendant

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ORDER

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/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney

Pursuant to the parties’ stipulation, and good cause appearing, Defendant’s time to file a
response to Plaintiff’s Opening Brief is extended to February 8, 2019. All other deadlines in the
Scheduling Order are extended accordingly.
IT IS SO ORDERED.

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Dated:

/s/ Barbara

January 7, 2019

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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Joint Stip. & Order for Ext.; 1:17-cv-01611-BAM

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