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Rodriguez v. Berryhill, 2:19-cv-00158-EFB. (2019)

Court: District Court, E.D. California Number: infdco20190607d74 Visitors: 3
Filed: Jun. 06, 2019
Latest Update: Jun. 06, 2019
Summary: STIPULATION AND PROPOSED ORDER FOR AN EXTENSION OF TIME FOR PLAINTIFF TO FILE HIS OPENING BRIEF EDMUND F. BRENNAN , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that Plaintiff shall have an extension of time of thirty (30) days to file his Opening Brief motion for summary judgment and/or remand, which will concomitantly extend the other deadlines in the Court's Scheduling Order (Dkt. 3). This is Plaintiff's first request for exten
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STIPULATION AND PROPOSED ORDER FOR AN EXTENSION OF TIME FOR PLAINTIFF TO FILE HIS OPENING BRIEF

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that Plaintiff shall have an extension of time of thirty (30) days to file his Opening Brief motion for summary judgment and/or remand, which will concomitantly extend the other deadlines in the Court's Scheduling Order (Dkt. 3). This is Plaintiff's first request for extension to file his Opening Brief.

There is good cause for this request. This case is an appeal of Defendant's denial of Plaintiff's claim for Social Security Disability benefits; Plaintiff intends on raising several fact-intensive issues as assignments of error. Defendant has filed the certified administrative transcript, which is over 1,700 pages in length. Based on the extensive record and the nature of the errors raised, the parties hereby stipulate that Plaintiff shall have an extension of thirty (30) days in order to fully present the issues and relevant facts. Based on the Court's Scheduling Order, the due dates on the subsequent briefing will be modified accordingly.

Respectfully submitted, Dated: June 4, 2019 MEGHAN LAMBERT Osterhout Berger Disability Law, LLC Attorney for Plaintiff Dated: June 4, 2019 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Acting Regional Chief Counsel, Region IX, Social Security Administration By: Michael K. Marriott (*as authorized by email on June 3, 2019) Special Assistant U.S. Attorney Attorneys for Defendant

ORDER

APPROVED AND SO ORDERED.

Source:  Leagle

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