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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1 2 3 4 5 6 7 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: (415) 977-8958 Facsimile: (415) 744-0134 E-Mail: 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 JESSICA GUTIERREZ ROMINGQUET, 14 Plaintiff, 15 vs. 16 17 18 NANCY A. BERRYHILL, Acting Commissioner of Social Security, 19 ) Case No.: 2:16-cv-01249-CKD ) ) ) JOINT STIPULATION AND ORDER ) FOR EXTENSION OF TIME ) ) ) ) ) ) ) Defendant. 20 Defendant Nancy A. Berryhill,1 Acting Commissioner of Social Security (“Defendant”) 21 22 respectfully requests that the Court extend the time for Defendant to file her Opposition to 23 Plaintiff’s Opening Brief, due on February 10, 2017, by 28 days, through and including March 24 10, 2017. This is the Commissioner’s first request for an extension of time in this matter. 25 An extension of time is needed in order to prepare Defendant’s opposition because of the 26 drafting attorney’s exceptionally heavy workload during the month of February and the week of 27 1 28 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 1 1 February 6th in particular, in which the drafting attorney has a Ninth Circuit merits brief and 2 three district court merits briefs due. This request is made in good faith with no intention to 3 unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel, who had no 4 objection to this request, on February 9, 2017. 5 Respectfully submitted this 9th day of February, 2017. 6 7 8 By: /s/* Shellie Lott SHELLIE LOTT *by email authorization on 2/9/17 9 10 Attorney for Plaintiff 11 PHILIP A. TALBERT United States Attorney DEBORAH STACHEL Regional Chief Counsel, Region IX 12 13 14 By: /s/ Urmila Taylor URMILA TAYLOR Special Assistant United States Attorney 15 16 OF COUNSEL: D. ADAM LAZAR, CSBN 237485 Assistant Regional Counsel, Region IX 17 18 Attorneys for Defendant 19 20 21 ORDER 22 23 IT IS SO ORDERED. 24 Dated: February 13, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 25 26 27 28 Stipulation and Proposed Order for Extension of Time 2:16-cv-01249-CKD 2

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