(SS)Agans v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 9/11/2020 EXTENDING Time to 10/14/2020, for Defendant to file a cross-motion for summary judgment and opposition to 13 Motion for Summary Judgment. (York, M)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
ELLINOR R. CODER, CSBN 258258
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CHANDRA TARA AGANS,
Plaintiff,
vs.
ANDREW SAUL,
Commissioner of Social Security,
Defendant.

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) Case No.: 2:20-cv-00508-AC
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) STIPULATION FOR AN EXTENSION OF
) TIME; [PROPOSED] ORDER
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Pending the Court’s approval, IT IS HEREBY STIPULATED, by and between the

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parties, through their respective counsel of record, that the time for Defendant to respond to

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Plaintiff’s Motion for Summary Judgement be extended thirty (30) days from September 14,

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2020, up to and including October 14, 2020. This is the parties’ first stipulation for an extension,

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and this case was previously stayed pursuant to General Order 615 pending the Commissioner’s

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preparation of the certified administrative record (Dkt. 9). Defendant requests this extension in

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order to further consider the issues raised in Plaintiff’s Motion for Summary Judgment and

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coordinate with senior attorneys to review the Commissioner’s draft brief. This matter was

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recently assigned to the undersigned counsel following the departure of the assigned defense

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counsel (Dkt. 15 [September 8, 2020 notice of appearance]).

Stip. for Ext.; 2:20-cv-00508-AC

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

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Respectfully submitted,
Dated: September 11, 2020

/s/ Lawrence D. Rohlfing
(*as authorized via e-mail on September 11, 2020)
LAWRENCE D. ROHLFING
Attorney for Plaintiff

DATED: September 11, 2020

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/ Ellinor R. Coder
ELLINOR R. CODER
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER
Pursuant to the parties’ stipulation, IT IS SO ORDERED that Defendant shall have an
extension, up to and including October 14, 2020, to respond to Plaintiff’s Opening Brief.

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DATED: September 11, 2020

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Stip. for Ext.; 2:20-cv-00508-AC

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