Ybarra v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER for an Extension of Time of 45 Days for Defendant's Response to Plaintiff's Opening Brief, signed by Magistrate Judge Jeremy D. Peterson on 11/1/18. ( Responses due by 12/13/2018) (Martin-Gill, S)

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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

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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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TONY YBARRA,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:18-cv-00064-JDP
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 45 DAYS FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S OPENING BRIEF

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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 shall have an extension of time of 45 additional days to

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respond to Plaintiff’s opening brief. The current due date is October 29, 2018. The new due

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date will be December 13, 2018.

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

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

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Plaintiff’s opening brief, Defendant’s counsel has been addressing her full workload of district

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court cases and other cases including other cases that were previously extended. In addition,

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new matters that were not previously anticipated and could not be assigned to another attorney,

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including a hearing with about a week’s notice in advance, created some crowding of the briefing

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schedule around the due date of this case. Moreover, Defendant’s counsel continues to have a

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full workload for the next few weeks. Thus, Defendant is respectfully requesting additional time

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up to and including December 13, 2018, to fully review the record and research the issues

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presented by Plaintiff’s opening brief. This request is made in good faith with no intention to

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unduly delay the proceedings.

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Respectfully submitted,
Date: October 29, 2018
s/ Lawrence D. Rohlfing by C.Chen*
(As authorized by email on 10/29/2018)
LAWRENCE D. ROHLFING
Attorneys for Plaintiff

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Date: October 29, 2018

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MCGREGOR W. SCOTT
United States Attorney

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By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U.S. Attorney

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Attorneys for Defendant

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IT IS SO ORDERED.

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Dated:

November 1, 2018
UNITED STATES MAGISTRATE JUDGE

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