Owen v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 6/29/17, ORDERING that the time for Defendant to file her Opposition to Plaintiff's Opening Brief is EXTENDED to 7/24/2017. (Kastilahn, A)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARIAN OWEN,

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Plaintiff,
vs.

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NANCY A. BERRYHILL
Acting Commissioner of Social Security,

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) Case No.: 2:16-cv-00912-CMK
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) JOINT STUPULATION AND ORDER
) FOR EXTENSION OF TIME
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Defendant.

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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)
respectfully requests that the Court extend the time for Defendant to file her Opposition to
Plaintiff’s Opening Brief, due on June 23, 2017, by 30 days, through and including Monday ,
July 24, 2017 (30 days falls on the preceding weekend). This is the Commissioner’s second
request for an extension of time in this matter.
Counsel for Defendant is getting married on June 24, which has caused significant
additional pressure on counsel’s schedule. In addition, an extension of time is needed in order to
prepare Defendant’s opposition because of counsel’s workload in the current two-week period,

Stipulation for Extension of Time; 2:16-cv-00912-CMK

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including a Ninth Circuit answering brief, another summary judgment motion, an EAJA

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opposition, and a motion to remand, in addition to the brief due in this matter.

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This request is made in good faith with no intention to unduly delay the proceedings.

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Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this request, on June

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21, 2017.

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Respectfully submitted,
Dated: June 21, 2017

PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney

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Attorneys for Defendant

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/s/ Linda Ziskin*
LINDA ZISKIN
(*by email authorization on June 21, 2017)

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Attorney for Plaintiff

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Dated: June 21, 2017

By:

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ORDER

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IT IS SO ORDERED.

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Dated: June 29, 2017

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Stipulation for Extension of Time; 2:16-cv-00912-CMK

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