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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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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MARISELA RAMOS,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL
Acting Commissioner of Social Security,

) Case No.: 2:17-cv-01007-CMK
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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”)

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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 November 20, 2017, by 30 days,

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through and including December 20, 2017. This is the Commissioner’s first request for an

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

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Stipulation for Extension of Time; 2:17-cv-01007-CMK 1

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intention to unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel,

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who had no objection to this request, on November 17, 2017.

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Respectfully submitted,
Dated: November 17, 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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ORDER

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IT IS SO ORDERED.

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Dated: November 28, 2017

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Dated: November 28, 2017

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Stipulation for Extension of Time; 2:17-cv-01007-CMK 2