Elvira Garcia v. Commissioner of Social Security

Filing 21

STIPULATION AND ORDER re 18 . STIPULATION WITH PROPOSED ORDER for Extension of Time to File Answer and Certified Administrative Record filed by Elvira Alejandre Ponce Garcia, Commissioner of Social Security. Signed by Magistrate Judge Kandis A. Westmore on 10/24/18. (sisS, COURT STAFF) (Filed on 10/24/2018)

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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 GARCIA,
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 October 11, 2018 to October 24, 2018. This is

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

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

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Administrative Record (CAR) and for attorney review following receipt of the CAR to prepare

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the Answer and/or responsive pleading. Defendant makes this request in good faith with no

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intention to unduly delay the proceedings. Defendant apologizes for the belated request for

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extension, but was out on sick leave from the flu/acute pneumonia and sought an additional

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JS for Extension of Time and PO;

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

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extension of time as soon as reasonably practicable. The parties further stipulate that the Court’s

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Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: October 24, 2018

/s/ Steven Rosales
(*as authorized by email by legal assistant E. Perez
on October 23, 2018)
STEVEN ROSALES
Attorney for Plaintiff

Dated: October 24, 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

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ORDER
APPROVED AND SO ORDERED:

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10/24/18
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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