Elvira Garcia v. Commissioner of Social Security

Filing 17

STIPULATION AND ORDER re 16 . STIPULATION WITH PROPOSED ORDER for Extension of Time to File Certified Administrative Record and Answer filed by Elvira Alejandre Ponce Garcia, Commissioner of Social Security Answer due by 10/11/2018. Signed by Magistrate Judge Kandis A. Westmore on 9/17/18. (sisS, COURT STAFF) (Filed on 9/17/2018)

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ALEX G. TSE, CSBN 152348
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
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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NORTHERN DISTRICT OF CALIFORNIA

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ELVIRA ALEJANDRE PONCE,
Plaintiff,

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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security

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Defendant.

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Case No.: 4:18-cv-01764-KAW
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME TO FILE AND SERVE
ANSWER, CERTIFIED
ADMINISTRATIVE RECORD, AND TO
MODIFY BRIEFING SCHEDULE.

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for Defendant to file the certified administrative record (CAR) and Answer to

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Plaintiff’s Complaint be extended from September 11, 2018 to October 11, 2018. This is

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Defendant’s first request for extension. Good cause exists to grant Defendant’s request for

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extension. Defendant needs additional time for the preparation of the paper Certified

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Administrative Record (CAR). Defendant also needs additional time for attorney review

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following receipt of the CAR to prepare the Answer and/or responsive pleading. Defendant

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makes this request in good faith with no intention to unduly delay the proceedings.

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///

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///
JS for Extension of Time and PO;

Case No. 4:18-cv-01764-KAW

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

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Respectfully submitted,

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Dated: September 11, 2018

/s/ Steven Rosales
(*as authorized by email on September 11, 2018)
KRISTINE CHAPPELL
Attorney for Plaintiff

Dated: September 11, 2018

ALEX G. TSE
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER

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APPROVED AND SO ORDERED:

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9/17/18
DATED:_______________________

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_____________________________________
THE HONORABLE KANDIS A. WESTMORE
UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time and PO;

Case No. 4:18-cv-01764-KAW

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