Rygg v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on 8/16/2017 ORDERING the Commissioner of Social Security to respond to the 16 Motion for Summary Judgment by 8/31/2017. (Michel, G.)

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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 STUPULATION 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 a responsive pleading to
Plaintiff’s opening brief, originally due on August 17, 2017, by 15 days, through and including
Friday, August 31, 2017. This is the Commissioner’s second request for an extension of time in
this matter.
A brief extension of time is needed because of the unusual and complex nature of the
underlying decision complained of, including a partial award of benefits and a finding of medical
improvement, which is requiring additional review by the agency. This request is made in good
faith with 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 August 11, 2017.

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Respectfully submitted,
Dated: August 15, 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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By: /s/ David Linden*
DAVID LINDEN
(*by email authorization on August 11, 2017)

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Attorney for Plaintiff

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Dated: August 15, 2017

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ORDER

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IT IS SO ORDERED.
Dated: August 16, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE