Timothy A. Piller v. Commissioner of Social Security

Filing 14

Stipulation and Order for Defendant's first extension of time to respond to Plaintiff's Motion for Remand, signed by Magistrate Judge Erica P. Grosjean on 1/22/2019. (Rosales, O.)

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McGREGOR W. SCOTT
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY (CBSN 263027)
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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TIMOTHY AUSTIN PILLER,
Plaintiff,

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vs.
NANCY A. BERRYHILL, Acting
Commissioner Of Social Security,
Defendant.

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CIVIL NO. 1:18-cv-00548-EPG
STIPULATION AND ORDER FOR
DEFENDANT’S FIRST EXTENSION OF
TIME TO RESPOND TO PLAINTIFF’S
MOTION FOR REMAND
(ECF No. 13)

IT IS HEREBY STIPULATED, by and between Timothy Austin Piller (“Plaintiff”) and Nancy

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A. Berryhill, Acting Commissioner of Social Security (“Defendant”) (collectively, the “Parties”), by and

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through their respective counsel of record, that Defendant shall have an extension of time of 45 days to

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respond to Plaintiff’s motion for remand and/or to file any cross-motion on or before March 4, 2019.

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Any reply thereto would be due on or before March 18, 2019. This is the first extension of time

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requested in the above-captioned matter of time requested in the above-captioned matter. Defendant
requests this additional time because she inadvertently miscalendered this case and has 14 motions for
summary judgment due and two oral argument prior to the extended deadline. The undersigned
STIPULATION & ORDER

CASE NUMBER 1:18-CV-00548-EPG

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apologizes to the Court and to Plaintiff for the timing of this request and the inconvenience. The Parties
further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Date: January 22, 2019

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CERNEY KREUZE & LOTT, LLP
By: /s/ Shellie Lott*
SHELLIE LOTT
Attorneys for the Plaintiff
(*Authorized by email on January 22, 2019)

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Date: January 22, 2019

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McGREGOR W. SCOTT
Acting United States Attorney

By: /s/ Sharon Lahey
SHARON LAHEY
Special Assistant United States Attorney

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STIPULATION & ORDER

CASE NUMBER 1:18-CV-00548-EPG

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ORDER
Pursuant to the stipulation of the parties (ECF No. 13), and good cause appearing,
IT IS ORDERED that the deadline for Defendant to respond to Plaintiff’s motion for summary
judgment and/or to file any cross-motion is extended to March 4, 2019. Any reply shall be filed by
March 18, 2019. The Court’s Scheduling Order (ECF No. 5) is modified accordingly.

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IT IS SO ORDERED.

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Dated:

January 22, 2019

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/s/
UNITED STATES MAGISTRATE JUDGE

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STIPULATION & ORDER

CASE NUMBER 1:18-CV-00548-EPG