Moon v. Commisioner of Social Security

Filing 18

STIPULATION and ORDER TO EXTEND TIME signed by Magistrate Judge Allison Claire on 4/8/16 ORDERING that the time for filing of Defendant's opposition to Plaintiff's opening brief is EXTENDED from 4/11/16 to 5/11/2016. (Mena-Sanchez, L)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL – CSBN 230138
Acting Regional Chief Counsel, Region IX
Social Security Administration
RICHARD M. RODRIGUEZ
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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SACRAMENTO DIVISION
ANDY ALLEN MOON,

) Case No: 2:14-cv-00861-AC
)
) STIPULATION AND ORDER TO EXTEND
Plaintiff,
) TIME
)
vs.
)
)
CAROLYN W. COLVIIN, Acting Commissioner )
)
of the Social Security Administration,
)
)
Defendant.
)

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The parties, through their respective counsel, stipulate the time for filing of defendant’s
opposition to plaintiff’s opening brief be extended from April 11, 2016, to May 11, 2016.

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This is Defendant’s first request for an extension of time to file a response to Plaintiff’s

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opening brief. Defendant needs the additional time to further review the voluminous file in this case in

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order to properly respond to the issues raised by Plaintiff in his opening brief.

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Further, the undersigned briefing schedule for the month of April has been exceptionally heavy,
and the unexpected assignment of a sensitive employee relations matter has left an insufficient amount
of time in which to prepare Defendant’s response.
Plaintiff has had one extension of time of 20 days in which to file his opening brief.

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Plaintiff’s reply brief, shall be filed within 21 days from receipt of Defendant’s response.
Stipulation and Order for Extension of Time
1:15-CV-00078-JLT

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Counsel for Defendant conferred with Plaintiff’s counsel via email, who has no opposition to
the requested extension request on April 7, 2016.
Respectfully submitted,

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Dated: April 7, 2016

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL, Acting
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant U.S. Attorney
Attorneys for Defendant

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Dated: April 7, 2016

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/s/Robert C. Weems, CSBN 148156
As authorized by email
ROBERT C. WEEMS, ESQ.
Attorney for Plaintiff

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IT IS SO ORDERED:

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Dated: April 8, 2016
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Stipulation and Order for Extension of Time

1:15-CV-00078-JLT

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