Lamb v. Commissioner of Social Security

Filing 22

STIPULATION AND ORDER signed by Magistrate Judge Craig M. Kellison on 4/12/2017 ORDERING the Commissioner of Social Security to respond to the 16 Motion for Summary Judgment/Remand by 5/2/2017; ORDERING the plaintiff to file any reply by 5/23/2017. (Michel, G.)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL, CA SBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
THEOPHOUS H. REAGANS, CSBN 189450
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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UNITED STATES DISTRICT COURT

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EASTER DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION
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ANSWER

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DEBI JEAN LAMB,

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Plaintiff,
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vs.
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NANCY A. BERRYHILL, 1
Acting Commissioner of Social Security,

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Defendant.

CIVIL NO. 2:16-cv-01227-CMK
STIPULATION FOR EXTENSION OF
TIME FOR DEFENDANT TO
RESPOND TO PLAINTIFF’S
OPENING BRIEF

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IT IS HEREBY STIPULATED, by and between Debi Jean Lamb (Plaintiff) and Nancy A.
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Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel
of record, that Defendant shall have an extension of time of thirty (30) days to deliver her Motion for
Summary Judgment and in Opposition to Plaintiff’s Motion for Summary Judgment. The current due
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Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d) of the
Federal Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Acting Commissioner
Carolyn W. Colvin as the defendant in this suit. No further action needs to be taken to continue this suit
by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).
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Stip. & Prop. Order for Ext.; 16-cv-1227-CMK

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date is April 3, 20117. The new due date will be May 2, 2017. The parties further stipulate that all other
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dates will be extended accordingly, and Plaintiff’s reply will be due to Defendant by May 23, 2017. This
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is the second extension of time requested by Defendant in this matter. Defendant requested an extension
previously because the responsible attorney was on leave due to illness. The case was reassigned to
another attorney, Brenda Pullin, who has also been on leave due to illness. Defendant requests this
extension because the attorney responsible for briefing this case has been out of the office intermittently
for the last several weeks due to illness. This request is made in good faith by the supervisor of the
responsible attorney of record with no intention to unduly delay the proceedings.
Respectfully submitted,

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Dated: March 28, 2017

By: /s/* Steven G. Rosales
Steven G. Rosales
12631 East Imperial Highway, C-115
Santa Fe Springs, CA 90670
*by email authorization on 3/28/17

Dated: March 28, 2017

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE SATCHEL
Regional Chief Counsel, Region IX

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By: /s/ Theophous H. Reagans
THEOPHOUS H. REAGANS
Special Assistant United States Attorney

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Attorneys for Defendant

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Stip. & Prop. Order for Ext.; 16-cv-1227-CMK

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ORDER

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GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, IT IS SO ORDERED.
DEFENDANT SHALL FILE HER RESPONSE TO PLAINTIFF’S OPENING BRIEF ON OR
BEFORE MAY 2, 2017. ANY REPLY THERETO SHALL BE FILED ON OR BEFORE MAY
23, 2017.

Dated: April 12, 2017

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Stip. & Prop. Order for Ext.; 16-cv-1227-CMK