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Debra L. Nicholson v. Michael J. Astrue

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


November 5, 2012

DEBRA L. NICHOLSON, PLAINTIFF,
v.
MICHAEL J. ASTRUE, COMMISSIONER OF SOCIAL SECURITY,
DEFENDANT.

The opinion of the court was delivered by: Barbara A. McAuliffe United States Magistrate Judge

STIPULATION AND ORDER EXTENDING TIME FOR PLAINTIFF TO FILE OPENING BRIEF

The parties hereby stipulate by counsel, subject to the approval of the court, that Plaintiff shall have a FIRST extension of time of 30 days to file Opening Brief up to and including December 4, 2012. This extension is being sought because the undersigned counsel for the Plaintiff has experienced a significant increase in workload and scheduling issues. Given this situation, Counsel respectfully requests that 30 additional days are necessary in order to complete the Opening Brief.

Additionally, the parties hereby stipulate by counsel, subject to the approval of the court, that Defendant shall have a FIRST

Extension of Time to File Opening Brief extension of time of 45 days to file Responsive Brief up to an including January 18, 2013. This extension is being sought because the undersigned counsel for the Defendant will be on vacation and faces additional deadlines. Given this situation, Counsel respectfully requests that 45 additional days are necessary in order to complete the Responsive Brief, in light of Plaintiff's proposed deadline of December 4, 2012.

The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

Respectfully submitted, DATED: November 1, 2012 BENJAMIN B. WAGNER United States Attorney DONNA L. CALVERT Acting Regional Chief Counsel, Region IX Social Security Administration _/s/ Mary Beth O'Connor*___ MARY BETH O'CONNOR Special Assistant US Attorney [*By email authorization on November 1, 2012] Attorneys for Defendant DATED: November 1, 2012 LAW OFFICES OF BINDER AND BINDER _/s/ Shanny J. Lee______ SHANNY J. LEE Attorneys for Plaintiff

Order

Based on the Stipulation of the parties, and for good cause shown, Plaintiff shall have up to and including December 4, 2012 to file her opening brief. Additionally, Defendant shall have up to and including January 18, 2013 to file his responsive brief. IT IS SO ORDERED.

20121105

© 1992-2012 VersusLaw Inc.



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