Rhoades v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 1/28/2019 EXTENDING Defendant's time to respond to 14 Motion for Summary Judgment to 2/7/2019. (Huang, H)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ALLISON J. CHEUNG, CSBN 244651
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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JEFFREY R. RHOADES,
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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.: 2:18-cv-01264-KJN
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) STIPULATION AND ORDER FOR
) 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, with the Court’s approval, that Defendant shall have a 10-day extension of

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time, from January 28, 2019 to February 7, 2019, to respond to Plaintiff’s Motion for Summary

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Judgment (Dkt. No. 14).

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This is Defendant’s first request for an extension of time. Defendant submits that good

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cause exists for this extension because the parties are engaged in settlement discussions. If the

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parties cannot agree, Defendant anticipates filing a Motion to Remand, which would reduce the

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number of issues that this Court will need to resolve and largely focus on the issue of remedy.

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Defendant’s counsel will endeavor to complete the response as soon as possible and by no later

Stip. for Ext. of Time; No. 2:18-cv-01264-KJN

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than February 7. This request is made in good faith and 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. The parties
further stipulate that the deadline for any reply by Plaintiff will be extended accordingly.

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Respectfully submitted,

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Dated: January 25, 2019

THE METSKER LAW FIRM

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By:

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/s/ John Metsker*
John Metsker
Attorney for Plaintiff
[*As authorized by email on January 25, 2019]

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Dated: January 25, 2019

Respectfully submitted,

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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/ Allison J. Cheung
ALLISON J. CHEUNG
Special Assistant U.S. Attorney
Attorneys for Defendant

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Stip. for Ext. of Time; No. 2:18-cv-01264-KJN

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.
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Dated: January 28, 2019

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Stip. for Ext. of Time; No. 2:18-cv-01264-KJN

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