Baugh v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 12/4/2017 EXTENDING Time until 1/12/2018, for Defendant to Respond to 10 Motion for Summary Judgment. (York, M)
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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
MARGARET BRANICK-ABILLA, CSBN 223600
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8929
Facsimile: (415) 744-0134
E-Mail: Margaret.Branick-Abilla@ssa.gov
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Attorneys for Defendant
UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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ALEXANDRIA BAUGH,
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Plaintiff,
vs.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
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Defendant.
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Case No.: 2:17-cv-01382-AC
STIPULATION & [PROPOSED] ORDER
FOR EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties through their respective
counsel of record, that Defendant shall have a 35-day extension of time, from December 8, 2017,
to January 12, 2018, for Defendant to respond to Plaintiff’s Motion for Summary Judgment. All
other dates in the Court’s Scheduling Order shall be extended accordingly.
This is Defendant’s first request for an extension of time. Defendant respectfully submits
that good cause exists for the requested extension because Defendant’s counsel requires
additional time to review the record, to evaluate the issues raised in Plaintiff’s Motion for
Summary Judgment, to determine whether options exist for settlement, to prepare Defendant’s
Stipulation & PO; Case No.: 2:17-cv-01382-AC
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response to Plaintiff’s Motion if settlement is not possible, and to accommodate competing
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workloads. This request is made in good faith with no intention to unduly delay the proceedings.
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Plaintiff does not oppose the requested extension.
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Respectfully submitted,
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Dated: December 1, 2017
LAW OFFICE OF NANCY MCCOMBS
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By: /s/ Nancy K. McCombs*
NANCY K. MCCOMBS
Attorneys for Plaintiff
[*As authorized by e-mail on Dec. 1, 2017]
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Dated: December 4, 2017
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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
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By: /s/ Margaret Branick-Abilla
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MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant
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[PROPOSED] ORDER
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Pursuant to stipulation, IT IS SO ORDERED.
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Dated: December 4, 2017
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Stipulation & PO; Case No.: 2:17-cv-01382-AC
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