Gnibus v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 4/27/16 ORDERING that Defendant shall have an extension of time to 5/4/2016 to respond to Plaintiff's opening brief. (Kastilahn, A)
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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, SBN PA 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8931
Facsimile: (415) 744-0134
E-Mail: Chantal.Jenkins@ssa.gov
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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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LYNN EILEEN GNIBUS,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.
) Case No.: 2:15-CV-01669-AC
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) STIPULATION AND PROPOSED ORDER
) FOR A SECOND 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 May 4, 2016 to respond to
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Plaintiff’s opening brief. The current due date is April 20, 2016. Defendant respectfully
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requests this additional time due to a heavy workload. Defendant’s counsel just argued before
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the Ninth Circuit and is currently working on a motion in another matter before the Ninth
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Circuit. In addition, Defendant’s counsel is responsible for managing and briefing forty-eight
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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
accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.
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Respectfully submitted,
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LAW OFFICES OF LAWRENCE D. ROHLFING
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Dated: April 19, 2016
/s/ Vijay J. Patel by Chantal R. Jenkins*
Vijay J. Patel
As authorized via email on April 19, 2016
Attorney for Plaintiff
Dated: April 19, 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: April 27, 2016
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