Rygg v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 7/6/17, ORDERING that the time for Defendant to file her Opposition to Plaintiff's Opening Brief is EXTENDED to 8/17/2017. (Kastilahn, A)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SONJA RYGG,

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Plaintiff,
vs.

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NANCY A. BERRYHILL
Acting Commissioner of Social Security,

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) Case No.: 2:16-cv-02737-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, Acting Commissioner of Social Security (“Defendant”)
respectfully requests that the Court extend the time for Defendant to file her Opposition to
Plaintiff’s Opening Brief, originally due on July 3, 2017, by 45 days, through and including
Thursday, August 17, 2017. This is the Commissioner’s first request for an extension of time in
this matter.
An extension of time is needed in order to prepare Defendant’s opposition because
counsel was married on June 24, which has caused significant additional pressure on counsel’s
schedule. Counsel’s workload in the current two-week period further includes three summary
judgment motions and multiple discovery deadlines for an Equal Employment Opportunity

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(EEO) hearing, in addition to the brief due in this matter. This request is made in good faith with

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no intention to unduly delay the proceedings.

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Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this request,
on June 30, 2017.

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Respectfully submitted,
Dated: June 30, 2017

PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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

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Attorneys for Defendant

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/s/ David Linden*
DAVID LINDEN
(*by email authorization on June 30, 2017)

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Attorney for Plaintiff

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Dated: June 30, 2017

By:

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ORDER

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IT IS SO ORDERED.

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Dated: July 6, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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