Yang v. CSS

Filing 16

STIPULATION and ORDER TO EXTEND TIME - Order signed by Magistrate Judge Dennis L. Beck on 3/11/2010. (Hernandez, M)

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1 2 3 4 5 6 7 8 9 10 BENJAMIN WAGNER United States Attorney LUCILLE GONZALES MEIS Regional Chief Counsel, Region IX Social Security Administration ELIZABETH FIRER Special Assistant United States Attorney 333 Market Street, Suite 1500 San Francisco, California 94105 Telephone: (415) 977-8937 Facsimile: (415) 744-0134 E-Mail: Elizabeth.Firer@ssa.gov Attorneys for Defendant UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEE YANG, ) ) Plaintiff, ) v. ) ) MICHAEL J. ASTRUE, ) Commissioner of ) Social Security, ) ) Defendant. ) _________________________________) CIVIL NO. 1:09-CV-00790 DLB STIPULATION AND ORDER The parties hereby stipulate by counsel, with the Court's approval as indicated by issuance of the attached Order, that Defendant shall have an extension of time, up to and including March 31, 2010, to respond to Plaintiff's Opening Brief. This request is being made because, for the first two weeks of March, the undersigned counsel for the Commissioner has had a heavy work load including 5 district court briefs/responses due plus a Ninth Circuit mediation conference and a Ninth Circuit argument on Friday, March 12, 2010. In preparing for the oral argument, counsel has experienced an unexpected difficulty in that two of the senior attorneys scheduled to participate in her moot court were unable to participate due to a conflict that did not arise until it was too late to substitute other senior attorneys in the Commissioner's regional office. As a result of this unforseen conflict, the undersigned counsel for the Commissioner will not have the benefit of senior counsel in preparing for the oral argument and must expend additional time ensuring that she is properly prepared. She is thus unable to complete the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Commissioner's brief in and file it today as she had planned. Currently, counsel has 6 additional district court briefs due between March 15 and 31, 2010. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. Respectfully submitted, Dated: March 10, 2010 /s/ Laura L. Krank (As authorized via telephone) LAURA L. KRANK At torney for Plaintiff BENJAMIN WAGNER United States Attorney LUCILLE GONZALES MEIS Regional Chief Counsel, Region IX Social Security Administration /s/ Elizabeth Firer ELIZABETH FIRER Special Assistant U.S. Attorney Attorneys for Defendant Dated: March 10, 2010 IT IS SO ORDERED. Dated: 9b0hie March 11, 2010 /s/ Dennis L. Beck UNITED STATES MAGISTRATE JUDGE 2 - Stip & Order Extending Def's Time

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