Romingquet v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 2/13/2017 ORDERING that the time for defendant to file her opposition to plaintiff's opening brief is EXTENDED to 3/10/2017. (Zignago, K.)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
URMILA TAYLOR, CSBN 234655
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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JESSICA GUTIERREZ ROMINGQUET,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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) Case No.: 2:16-cv-01249-CKD
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) JOINT STIPULATION AND ORDER
) FOR EXTENSION OF TIME
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Defendant.

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Defendant Nancy A. Berryhill,1 Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to

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Plaintiff’s Opening Brief, due on February 10, 2017, by 28 days, through and including March

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10, 2017. This is the Commissioner’s first request for an extension of time in this matter.

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An extension of time is needed in order to prepare Defendant’s opposition because of the

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drafting attorney’s exceptionally heavy workload during the month of February and the week of

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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).
Stipulation and Proposed Order for Extension of Time
2:16-cv-01249-CKD

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February 6th in particular, in which the drafting attorney has a Ninth Circuit merits brief and

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three district court merits briefs due. This request is made in good faith with no intention to

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unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel, who had no

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objection to this request, on February 9, 2017.

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Respectfully submitted this 9th day of February, 2017.

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By: /s/* Shellie Lott
SHELLIE LOTT
*by email authorization on 2/9/17

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Attorney for Plaintiff

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PHILIP A. TALBERT
United States Attorney
DEBORAH STACHEL
Regional Chief Counsel, Region IX

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By: /s/ Urmila Taylor
URMILA TAYLOR
Special Assistant United States Attorney

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OF COUNSEL:
D. ADAM LAZAR, CSBN 237485
Assistant Regional Counsel, Region IX

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Attorneys for Defendant

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ORDER

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IT IS SO ORDERED.

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Dated: February 13, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Proposed Order for Extension of Time
2:16-cv-01249-CKD

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