Easley v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 10/25/2017 ORDERING that the time for defendant to file her opposition to plaintiff's motion for summary judgment is CONTINUED to 11/23/2017. (Zignago, K.)

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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
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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ROY EASLEY,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL
Acting Commissioner of Social Security,

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Case No.: 2:17-cv-00475-CKD
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME

Defendant.

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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 Motion for Summary Judgment, originally due on October 24, 2017, by 30 days,

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through and including Thursday, November 23, 2017. This is the Commissioner’s first request

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for an extension of time in this matter.

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An extension of time is needed in order to prepare Defendant’s opposition because of

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counsel’s heavy workload during October. This request is made in good faith with no intention

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to unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel, who had no

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objection to this request, on October 23, 2017.

Stipulation for Extension of Time; 2:17-cv-00475-CKD 1

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Respectfully submitted,
Dated: October 23, 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/ Joseph C. Fraulob*
JOSEPH C. FRAULOB
(*by email authorization)

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Attorney for Plaintiff

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Dated: October 23, 2017

By:

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ORDER

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IT IS SO ORDERED.

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Dated: October 25, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stipulation for Extension of Time; 2:17-cv-00475-CKD 2