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Lee v. Berryhill, 1:18-01208-EPG. (2019)

Court: District Court, E.D. California Number: infdco20190618a14 Visitors: 4
Filed: Jun. 17, 2019
Latest Update: Jun. 17, 2019
Summary: STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE (ECF No. 17) ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her response to Plaintiff's opening brief with the Court by 30 days to July 31, 2019, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and
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STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE

(ECF No. 17)

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her response to Plaintiff's opening brief with the Court by 30 days to July 31, 2019, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and she requests it in good faith and without any intent to prolong proceedings unduly.

There is good cause for this extension request because counsel for Defendant is currently responsible for performing a range of tasks that preclude drafting the Commissioner's responsive brief by July 1, 2019, such as: drafting answering briefs in two Social Security cases pending before the Ninth Circuit; drafting briefs in Social Security cases before the district courts within the Ninth Circuit; negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act before the district courts within the Ninth Circuit; assisting with the training of a newly hired attorney in the agency's Office of the General Counsel, Region IX; and preparing for an arbitration scheduled for June 26, 2019, involving the agency and one of the agency's collective bargaining units.

Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay.

Respectfully submitted, Dated: June 17, 2019 PENA & BROMBERG By:/s/Asim H. Modi for Jonathan Omar Pena* JONATHAN OMAR PENA *Authorized by email on June 16, 2019 Attorney for Plaintiff Dated: June 17, 2019 McGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration By:/s/Asim H. Modi ASIM H. MODI Special Assistant United States Attorney Attorneys for Defendant

ORDER

Pursuant to the stipulation of the Parties (ECF No. 17), and finding good cause exists, IT IS ORDERED that the deadline for Defendant to respond to Plaintiff's opening brief is extended to July 31, 2019. All subsequent deadlines set forth in the Court's Scheduling Order (ECF No. 5) are modified accordingly.

IT IS SO ORDERED.

Source:  Leagle

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