Brown v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 1/27/2016 GRANTING the parties extension of time; Defendant shall have an extension of time to 2/17/2016 to respond to plaintiff's opening brief. (Reader, L)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
CHANTAL R. JENKINS, PA SBN 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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ROBERT BROWN,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

) Case No.: 2:15-CV-01430-CKD
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) STIPULATION AND ORDER
) FOR AN EXTENSION OF TIME
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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 shall have an extension of time to February 17, 2016 to
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respond to Plaintiff’s opening brief. The current due date is February 14, 2016. This is
Defendant’s first request for an extension. Defendant respectfully requests this additional time
due to a heavy workload. Defendant’s counsel has a Ninth Circuit brief due in February and has

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to represent the agency in a Ninth Circuit oral argument in another case that originally belonged
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to another attorney. In addition, Defendant’s counsel is currently responsible for managing and

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briefing forty-three other matters pending before the District Courts.
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This request is made in good faith with no intention to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified

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accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: January 26, 2016

/s/_Richard A. Whitaker by Chantal R. Jenkins*__
As authorized by Erika Ranson on behalf of Richard
A. Whitaker via email on January 26, 2016
Richard Allen Whitaker, Esq.
Attorney for Plaintiff

Dated: January 26, 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/ Chantal R. Jenkins___
CHANTAL R. JENKINS
Special Assistant United States Attorney

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ORDER

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APPROVED AND SO ORDERED:

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Dated: January 27, 2016

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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