Ramos v. Commisioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 11/28/17: The time for Defendant to file her Opposition to Plaintiff's Motion for Summary Judgment is extended by 30 days, through and including December 20, 2017.(Kaminski, H)

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1 2 3 4 5 6 7 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: (415) 268-5601 Facsimile: (415) 744-0134 E-Mail: adam.lazar@ssa.gov 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 MARISELA RAMOS, 13 Plaintiff, 14 vs. 15 16 17 18 NANCY A. BERRYHILL Acting Commissioner of Social Security, ) Case No.: 2:17-cv-01007-CMK ) ) ) JOINT STUPULATION AND ORDER ) FOR EXTENSION OF TIME ) ) ) ) ) ) ) Defendant. 19 20 Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”) 21 respectfully requests that the Court extend the time for Defendant to file her Opposition to 22 Plaintiff’s Motion for Summary Judgment, originally due on November 20, 2017, by 30 days, 23 through and including December 20, 2017. This is the Commissioner’s first request for an 24 extension of time in this matter. 25 26 An extension of time is needed in order to prepare Defendant’s opposition because of counsel’s heavy workload in October and November. This request is made in good faith with no 27 28 Stipulation for Extension of Time; 2:17-cv-01007-CMK 1 1 intention to unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel, 2 who had no objection to this request, on November 17, 2017. 3 4 5 Respectfully submitted, Dated: November 17, 2017 PHILIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 6 7 8 By: 10 /s/ Adam Lazar ADAM LAZAR Special Assistant U.S. Attorney 11 Attorneys for Defendant 9 12 13 14 ORDER 15 16 IT IS SO ORDERED. 17 Dated: November 28, 2017 18 Dated: November 28, 2017 19 20 21 22 23 24 25 26 27 28 Stipulation for Extension of Time; 2:17-cv-01007-CMK 2

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