Greyeagle v. Commissioner of Social Security

Filing 15

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 4/25/2017 ORDERING the Commissioner of Social Security to respond to the 13 Motion for Summary Judgment by 6/23/2017. (Michel, G.)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
ADAM LAZAR, CSBN 237485
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[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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RICHARD GREYEAGLE,
Plaintiff,

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

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Defendant.

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Case No.: 2:16-cv-02514-AC

JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME

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Defendant Nancy A. Berryhill, 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, originally due on April 24, 2017, by 60 days, through and including

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Friday, June 23, 2017. This is the Commissioner’s first request for an extension of time in this

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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, in which the attorney must conduct pre-trial,

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participate in a multi-day hearing, and draft post-hearing briefs for a recently-scheduled

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arbitration, in addition to the attorney’s regular district court workload and drafting two Ninth

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Stipulation for Extension of Time; 2:16-cv-02514-AC 1

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

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proceedings. Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this

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request, on April 24, 2017.

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Respectfully submitted this 24th day of April, 2017.

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

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By

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

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ORDER

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IT IS SO ORDERED.

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Date: April 25, 2017

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Stipulation for Extension of Time; 2:16-cv-02514-AC 2