Herghelian v. Commissioner of Social Security

Filing 15

Joint STIPULATION and ORDER for and Extension of Time, signed by Magistrate Judge Barbara A. McAuliffe on 3/7/2019. Pursuant to the parties' stipulation, and cause appearing, Defendant's time for responding to Plaintiff's Opening Brief is HEREBY EXTENDED to April 19, 2019. All other deadlines in the Court's Scheduling Order are extended accordingly. The parties are advised that no further extensions of time will be granted absent a demonstrated showing of good cause. (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. 1:18-cv-00864-BAM
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) JOINT STIPULATION AND ORDER FOR
) AN EXTENSION OF TIME
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STEVE HERGHELIAN,

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 March 6, 2019 to April 19, 2019. This is Defendant’s first request for an extension of time

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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 three 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.; 1:18-cv-00864-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 Arizona.

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

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time to review the 834-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: March 6, 2019

/s/ Beatrice Na for Jeffrey Duarte*
(* As authorized by Teresa Gowans via email on
March 6, 2019)
JEFFREY DUARTE

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Attorney for Plaintiff

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Dated: March 5, 2019

MCGREGOR W. SCOTT
United States Attorney

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By:

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Attorneys for Defendant

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

ORDER
Pursuant to the parties’ stipulation, and cause appearing, Defendant’s time for responding

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to Plaintiff’s Opening Brief is HEREBY EXTENDED to April 19, 2019. All other deadlines in

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the Court’s Scheduling Order are extended accordingly. The parties are advised that no further

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extensions of time will be granted absent a demonstrated showing of good cause.
IT IS SO ORDERED.
Dated:

/s/ Barbara

March 7, 2019

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A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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Joint Stip. & Order for Ext.; 1:18-cv-00864-BAM

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