(SS) Rivera v. Commissioner of Social Security

Filing 18

Stipulation and Order for a first extension of thirty days for Defendant's opposition to Plaintiff's brief, signed by Magistrate Judge Erica P. Grosjean on 2/16/2021. (Response due by 3/24/2021)(Rosales, O.)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
DANIEL P. TALBERT
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
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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JUAN JOSE RIVERA,

No. 1:20-cv-00428-EPG

Plaintiff,

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v.

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ANDREW SAUL,
Commissioner of Social Security,

STIPULATION AND ORDER FOR A FIRST
EXTENSION OF THIRTY DAYS FOR
DEFENDANT’S OPPOSITION TO
PLAINTIFF’S OPENING BRIEF

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Defendant.
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The parties stipulate by counsel that Defendant shall have an extension of thirty days, until

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March 24, 2021, to file his opposition to Plaintiff’s opening brief. Good cause exists for this

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extension, as explained below.

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The undersigned counsel for Defendant has been unable to prepare an opposition to

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Plaintiff’s brief, because he had to prepare for and present oral argument in two cases to the

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United States Court of Appeals for the Ninth Circuit this week, and draft and file answering briefs

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in two other cases. Counsel for Defendant is responsible also for reviewing briefs for two new

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attorneys in his office, one of whom will take this case for briefing. Additional time will be

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necessary to allow the new attorney assigned this case to review the record and draft a brief, and

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for counsel of record for Defendant to review and file that brief.
For all these reasons, Defendant requests an extension of thirty days to file his opposition
to Plaintiff’s opening brief. Plaintiff’s counsel has no objection to this request.
Respectfully submitted February 12, 2021.

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DATED: February 12, 2021

/s/ Jonathan Pena
JONATHAN PENA
(as authorized by email)
Attorney for Plaintiff

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McGREGOR W. SCOTT
United States Attorney

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DATED: February 12, 201

By

s/ Daniel P. Talbert
DANIEL P. TALBERT
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER
Pursuant to the stipulation of the parties (ECF No. 16), IT IS ORDERED that Defendant

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shall file a response to Plaintiff’s opening brief no later than March 24, 2021. All subsequent

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deadlines are extended accordingly.

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IT IS SO ORDERED.

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Dated:

February 16, 2021

/s/
UNITED STATES MAGISTRATE JUDGE

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