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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6 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: 415-268-5601 Fax: 415-744-0134 Adam.Lazar@ssa.gov 7 Attorneys for Defendant 1 2 3 4 5 8 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 RICHARD GREYEAGLE, Plaintiff, 13 14 15 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, 16 Defendant. 17 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-cv-02514-AC JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME 18 Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”) 19 20 respectfully requests that the Court extend the time for Defendant to file her Opposition to 21 Plaintiff’s Opening Brief, originally due on April 24, 2017, by 60 days, through and including 22 Friday, June 23, 2017. This is the Commissioner’s first request for an extension of time in this 23 matter. 24 An extension of time is needed in order to prepare Defendant’s opposition because of the 25 drafting attorney’s exceptionally heavy workload, in which the attorney must conduct pre-trial, 26 participate in a multi-day hearing, and draft post-hearing briefs for a recently-scheduled 27 arbitration, in addition to the attorney’s regular district court workload and drafting two Ninth 28 Stipulation for Extension of Time; 2:16-cv-02514-AC 1 1 Circuit briefs. This request is made in good faith with no intention to unduly delay the 2 proceedings. Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this 3 request, on April 24, 2017. 4 Respectfully submitted this 24th day of April, 2017. 5 6 PHILLIP A. TALBERT United States Attorney DEBORAH STACHEL Regional Chief Counsel, Region IX 7 8 9 By 10 11 /s/ Adam Lazar ADAM LAZAR Special Assistant U.S. Attorney Attorneys for Defendant 12 13 14 ORDER 15 16 IT IS SO ORDERED. 17 18 Date: April 25, 2017 19 20 21 22 23 24 25 26 27 28 Stipulation for Extension of Time; 2:16-cv-02514-AC 2

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