Plummer v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/7/18 ORDERING that Plaintiff shall have an extension of time to 6/14/18 to file his opening brief. (Mena-Sanchez, L)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
Chantal R. Jenkins, SBN PA 307531
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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SACRAMENTO DIVISION
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LARRY GENE PLUMMER,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

) Case No.: 2:17-cv-02414-CKD
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Plaintiff shall have an extension of time to June 14, 2018 to file his

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opening brief. The court previously granted Plaintiff’s extension to file his motion for summary

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judgment on or before May 9, 2018. On April 26, 2018, Plaintiff’s counsel sent a letter,

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notifying the office of Defendant’s counsel that the administrative record was missing medical

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records that were submitted to the Appeals Counsel. Defendant’s counsel received the letter on

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May 2 and subsequently instructed the Appeals Counsel to prepare a supplemental administrative

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record. Defendant’s counsel anticipates that the supplemental record will be filed and served on

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Plaintiff’s counsel within two weeks, May 17, 2018. Plaintiff’s counsel will then have 45 days

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to prepare the opening brief.

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This request is made in good faith with no intention to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified

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accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,
Dated: May 3, 2018

/s/ Ana L. Molleda by Chantal R. Jenkins*
Ana L. Molleda
As authorized via email on May 3, 2018
Attorney for Plaintiff

Dated: May 3, 2018

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

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ORDER

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APPROVED AND SO ORDERED.

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Dated: May 7, 2018

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE