Savage v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 5/25/17: Defendant shall file her Opposition to Plaintiff's Opening Brief on or before July 5, 2017. (Kaminski, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
GINA TOMASELLI, CSBN 267090
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO

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CARRIE RUTH SAVAGE,

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Plaintiff,

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v.
NANCY A. BERRYHILL,
Acting Commissioner of Social
Security,

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)
) Case No. 2:16-cv-01591-AC
)
) AMENDED UNOPPOSED MOTION
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) FOR FIRST EXTENSION OF TIME
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Defendant.

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IT IS HEREBY STIPULATED, by and between Carrie Ruth Savage (Plaintiff)

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and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and

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through their respective counsel of record, that Defendant shall have an extension of

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time of (30) days to file her Opposition to Plaintiff’s Opening Brief. The current due

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date is June 5, 2017. The new date will be July 5, 2017. An extension of time is needed

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because the attorney responsible for briefing this case recently returned from leave after

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having surgery and is continuing to catch up on her heavy case load. This request is
made in good faith with no intention to unduly delay the proceedings.
This is the first extension of time request by Defendant in the above-captioned
matter. The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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Date: May 23, 2017

LAW OFFICES OF LAWRENCE D. ROHLFING
By: /s/ Steven G. Rosales*
STEVEN G. ROSALES
Attorney for Plaintiff
(*As authorized by e-mail on May 23, 2017)

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Date: May 23, 2017

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PHILLIP A. TALBERT
United States Attorney

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/s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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Attorneys for Defendant

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ORDER

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GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, IT IS SO
ORDERED. DEFENDANT SHALL FILE HER OPPOSITION TO PLAINTIFF’S
OPENING BRIEF ON OR BEFORE JULY 5, 2017.

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DATED: May 25, 2017

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