Estrada v. Colvin

Filing 16

ORDER GRANTING 15 STIPULATION FOR EXTENSION OF TIME. Signed by Judge Edward J. Davila on 6/21/2017. (ejdlc2S, COURT STAFF) (Filed on 6/21/2017)

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BRIAN STRETCH
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
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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NORTHERN DISTRICT OF CALIFORNIA
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GRACIELA LIZARDI ESTRADA,
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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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Case No.: 5:16-cv-06998-EJD
JOINT STUPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME

Defendant.

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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to

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Plaintiff’s Opening Brief, originally due on June 15, 2017, by 30 days, through and including

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Monday, July 17, 2017 (30 days falls on the preceding weekend). This is the Commissioner’s

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first request for an extension of time in this matter.

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An extension of time is needed in order to prepare Defendant’s opposition because of the

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drafting attorney’s workload in the current two-week period, including a Ninth Circuit answering

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brief, two summary judgment motions, an EAJA opposition, and a motion to remand, in addition
to the brief due in this matter. In addition, counsel is getting married on June 24, which has
Stipulation for Extension of Time; 5:16-cv-06998-EJD

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caused significant additional pressure on counsel’s schedule. This request is made in good faith

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with no intention to unduly delay the proceedings.

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Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this request,
on June 21, 2017.

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Respectfully submitted,
Dated: June 21, 2017

BRIAN STRETCH
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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IT IS SO ORDERED.

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Date:

June 21, 2017

By:
THE HON. EDWARD J. DAVILA
UNITED STATES MAGISTRATE JUDGE

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Stipulation for Extension of Time; 5:16-cv-06998-EJD

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