Filed: Jun. 06, 2019
Latest Update: Jun. 06, 2019
Summary: STIPULATION FOR EXTENSION OF TIME AND ORDER ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Esther Diane Escudero (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that, with the Court's approval, Defendant shall have an extension of time of thirty (35) days to file her Opposition to Plaintiff's Opening Brief. The current due date is June 7, 2019. The new date will be July
Summary: STIPULATION FOR EXTENSION OF TIME AND ORDER ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Esther Diane Escudero (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that, with the Court's approval, Defendant shall have an extension of time of thirty (35) days to file her Opposition to Plaintiff's Opening Brief. The current due date is June 7, 2019. The new date will be July ..
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STIPULATION FOR EXTENSION OF TIME AND ORDER
ERICA P. GROSJEAN, Magistrate Judge.
IT IS HEREBY STIPULATED, by and between Esther Diane Escudero (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that, with the Court's approval, Defendant shall have an extension of time of thirty (35) days to file her Opposition to Plaintiff's Opening Brief. The current due date is June 7, 2019. The new date will be July 12, 2019. All other deadlines will extend accordingly.
Defense counsel needs an extension of time because she needs more time to draft the response, go through the necessary in-house reviews for newer attorneys, and manage her other cases. Counsel has seven other briefs due this month and is out of the office the first week of July. This request is made in good faith with no intention to delay unduly the proceedings. Counsel apologizes to the Court for any inconvenience this delay may cause.
This is Defendant's first request for an extension.
Respectfully submitted,
Dated: June 5, 2019 McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
By: /s/ S. Wyeth McAdam
S. WYETH McADAM
Special Assistant United States Attorney
Attorneys for Defendant
/s/
JONATHAN OMAR PENA
Attorney for Plaintiff
Pena & Bromberg, Attorneys at Law
(*As authorized via phone call on June 5, 2019)
ORDER
Pursuant to the stipulation of the parties (ECF No. 20) and finding good cause exists, IT IS ORDERED that Defendant shall file her response to Plaintiff's opening brief on or before July 12, 2019. All subsequent deadlines are accordingly extended.
IT IS SO ORDERED.
