Hagar v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 11/27/2018 STIPULATING that defendant shall file her opposition to plaintiff's opening brief on or before 12/27/2018. (Huang, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
S. WYETH MCADAM
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105-1545
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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CAROL LYNEE HAGAR,
Plaintiff,

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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-02381-DMC
STIPULATION FOR EXTENSION OF
TIME AND
ORDER

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IT IS HEREBY STIPULATED, by and between Carol Lynee Hagar (Plaintiff) and Nancy

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A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective

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counsel of record, that, with the Court’s approval, Defendant shall have an extension of time of

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thirty (30) days to file her Opposition to Plaintiff’s Opening Brief. The current due date is

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November 27, 2018. The new date will be December 27, 2018. All other deadlines will extend

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accordingly.

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Defense counsel needs an extension of time because the attorney responsible needs more
time to draft the response, go through the necessary in-house reviews for new attorneys, and

Stip. & Prop. Order for Ext., 2:17-cv-02381-DMC

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manage her other cases. This request is made in good faith with no intention to delay unduly the

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proceedings. Counsel apologizes to the Court for any inconvenience this delay may cause.

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This is Defendant’s first request for an extension.

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Respectfully submitted,

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Dated: November 27, 2018

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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/ S. Wyeth McAdam
S. WYETH MCADAM
Special Assistant United States Attorney
Attorneys for Defendant

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/s/ Shanny J. Lee
SHANNY J. LEE
Attorney for Plaintiff
Law Offices of Harry J. Binder and Charles E. Binder, P.C.
(*As authorized via e-mail on November 26, 2018)

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ORDER

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GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, DEFENDANT SHALL FILE
HER OPPOSITION TO PLAINTIFF’S OPENING BRIEF ON OR BEFORE DECEMBER 27,
2018.

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Dated: November 27, 2018
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DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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Stip. & Prop. Order for Ext., 2:17-cv-02381-DMC