Shanahan v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER 19 signed by Magistrate Judge Edmund F. Brennan on 9/24/2018 ORDERING Defendant's time for responding to Plaintiff's Motion for Summary Judgment 17 be extended by 31 days, from 9/21/2018 to 10/22/2018. Additionally, the Courts Scheduling Order shall be extended accordingly. (Cannarozzi, N)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHEA LITA BOND, SBN D.C. 469103
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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RITA SHANAHAN,
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Plaintiff,
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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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) Case No. 2:18-cv-00484-EFB
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) STIPULATION AND PROPOSED 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 Defendant’s time for responding to Plaintiff’s Motion for Summary

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Judgment be extended by 31 days, from September 21, 2018 to October 22, 2018. The parties

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further stipulate that the Court’s Scheduling Order shall be extended accordingly.

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This is Defendant’s first request for an extension of time to respond to Plaintiff’s motion.

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Defendant respectfully submits that good cause exists for the requested extension because

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Defendant’s counsel requires additional time to review the record, to evaluate the issues raised in

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Plaintiff’s brief, and to prepare Defendant’s response. This request is made in good faith and

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Stip. & Prop. Order for Ext.; 2:18-cv-00484-EFB

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with no intention to unduly delay the proceedings, and counsel apologizes for any
inconvenience. Plaintiff does not oppose Defendant’s request for an extension of time.

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Respectfully submitted,

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Dated: September 20, 2018

/s/ Lawrence D. Rohlfing*
(*as authorized via email on September 20, 2018)
LAWRENCE D. ROHLFING
Attorney for Plaintiff

Dated: September 20, 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/ Shea Lita Bond
SHEA LITA BOND
Special Assistant U.S. Attorney

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Attorneys for Defendant

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OF COUNSEL:
Allison J. Cheung
Assistant Regional Counsel, Region IX

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ORDER

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APPROVED AND SO ORDERED.
Dated: September 24, 2018.

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THE HONORABLE EDMUND F. BRENNAN
United States Magistrate Judge

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Stip. & Prop. Order for Ext.; 2:18-cv-00484-EFB

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