Spagel v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 1/26/2018 ORDERING the deadline for Defendant's response to 18 Motion for Summary Judgment is EXTENDED to 2/28/2018. (Washington, S)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: 415-744-0134
E-mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION
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JOSHUA SPAGEL,
Plaintiff,

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

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Defendant Nancy A. Berryhill, Acting Commissioner of the Social Security

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)
) Case No. 2:17-CV-00839-AC
)
) STIPULATION AND PROPOSED ORDER TO
) EXTEND DEFENDANT’S TIME TO FILE HER
) RESPONSIVE BRIEF
)
)
) (Defendant’s First Request)
)
)

Administration (“Defendant”) respectfully request the Court to extend the time for Defendant to

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file her response to Plaintiff’s Motion For Summary Judgment and/or Remand due on January
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29, 2017, by 30 days, through and including February 28, 2018.
\\\

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Stipulation to extend
Defendant’s time to respond
2:17-CV-00839-AC

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(1) An extension of time is needed as Defendant’s counsel is in the process of contacting

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his client, the Office of Hearing Operations (OHO) for the purposes of seeking settlement

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authority in this case.

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(2) The undersigned is requesting a 30-day extension to insure the necessary time for

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discussion with OHO, and for them to provide a response within the next 30 days.
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(3) In addition, the respective counsels will need additional time to negotiate the terms
of any settlement.
(4) Plaintiff’s Reply brief, if necessary will be due on March 14, 2018.
(5) Counsel for Defendant conferred with Plaintiff’s counsel by email, who has no

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opposition to the requested extension on January 25, 2018.
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(6) This request is made in good faith with no intention to unduly delay the proceedings.

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DATED: January 25, 2018

McGREGOR W. SCOTT
United States Attorney

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By:

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/s/ Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant U.S. Attorney
[e-mail]
Attorneys for Defendant
Nancy A. Berryhill,
Acting Commissioner of Social Security

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DATED: January 25, 2018

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/s/Cyrus Safa
.
By: Richard M. Rodriguez,
as authorized by email on January 25, 2018
CYRUS SAFA, ESQ., CSBN: 282971
Attorney for Plaintiff

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Stipulation to extend
Defendant’s time to respond
2:17-CV-00839-AC

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APPROVED AND SO ORDERED:

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Dated: January 26, 2018
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______________________________ ________
THE HONORABLE ALLISON CLAIRE
United States Magistrate Judge

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Stipulation to extend
Defendant’s time to respond
2:17-CV-00839-AC