(SS) Tuupoina v. Commissioner of Social Security

Filing 27

JOINT STIPULATION and ORDER for extension of time to respond to Plaintiff's Opening Brief signed by Magistrate Judge Gary S. Austin on 10/7/2019. (Lundstrom, T)

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7 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration TINA L. NAICKER, CSBN 252766 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov 8 Attorneys for Defendant 1 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 FRESNO DIVISION 12 13 14 15 16 17 DAVID TUUPOINA, Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:18-cv-01320-GSA JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S OPENING BRIEF. 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, 21 that the time for Defendant to respond to Plaintiff’s Opening Brief be extended from October 2, 22 2019 to October 3, 2019. This is Defendant’s third request for extension Good cause exists to 23 grant Defendant’s request for extension. Counsel for Defendant (Counsel) has been out of the 24 office on intermittent sick leave due to her ongoing health issues. Due to unanticipated leave, 25 Counsel needs additional time to adequately review the transcript and properly respond to 26 Plaintiff’s Motion for Summary Judgment. The parties further stipulate that the Court’s 27 Scheduling Order shall be modified accordingly. Defendant makes this request in good faith with 28 JS for Extension of Time and PO Case No. 1:18-cv-01320-GSA 1 1 no intention to unduly delay the proceedings. Counsel apologizes for the belated request, but 2 made her request as soon as reasonably practicable. 3 4 Respectfully submitted, 5 6 Dated: October 2, 2019 /s/ Kelsey Brown (*as authorized by email on October 2, 2019) KELSEY BROWN Attorney for Plaintiff Dated: October 2, 2019 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 7 8 9 10 11 12 13 By 14 15 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant 16 17 IT IS SO ORDERED. 18 Dated: 19 October 7, 2019 /s/ Gary S. Austin UNITED STATES MAGISTRATE JUDGE 20 21 22 23 24 25 26 27 28 JS for Extension of Time and PO Case No. 1:18-cv-01320-GSA 2

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