Bennett v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 9/21/17, ORDERING that Defendant shall have a two-week extension of time to 10/4/2017 to respond to Plaintiff's opening brief.(Kastilahn, A)

1
2
3
4
5
6
7

PHILLIP A. TALBERT
United States Attorney
DEBORAH STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
Chantal R. Jenkins, SBN PA 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

8
9

Attorneys for Defendant
UNITED STATES DISTRICT COURT

10
EASTERN DISTRICT OF CALIFORNIA
11
SACRAMENTO DIVISION
12
13
JEFFREY ALLEN BENNETT,
14
Plaintiff,
15
16
17
18

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

19

)
) Case No.: 2:17-cv-00555-EFB
)
) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
)
)
)
)
)
)
)

20
IT IS HEREBY STIPULATED, by and between the parties, through their respective
21
counsel of record, that Defendant shall have a two-week extension of time to October 4, 2017 to
22
respond to Plaintiff’s opening brief. This is Defendant’s first request for an extension of time.
23
Defendant respectfully requests this additional time due to workload. Defendant’s counsel has to
24
file a response to an appeal in an Equal Employment Opportunity Commission (EEOC) case and
25
a motion in another EEOC case within the next week. Defendant’s counsel also has an oral
26
argument for a social security district court case next week and several district court briefs due
27
within the next few weeks.
28

1

1
2

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

3

The parties further stipulate that the Court’s Scheduling Order shall be modified

4
5

accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.

6
7

Respectfully submitted,

8

Law Offices of Lawrence D. Rohlfing

9

Dated: September 20, 2017

/s/ Cyrus Safa by Chantal R. Jenkins*
CYRUS SAFA
*Enedina Perez on behalf of Cyrus Safa via phone
on September 20, 2017
Attorney for Plaintiff

Dated: September 20, 2017

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

10
11
12
13
14
15
16
17
By:

18
19

/s/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

20
21
22

ORDER

23
24

APPROVED AND SO ORDERED.

25
26
27

Dated: September 21, 2017.

_______________________________________
THE HON. EDMUND F. BRENNAN
United States Magistrate Judge

28

2