Rams v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER for extension of time, signed by Magistrate Judge Gary S. Austin on 8/21/2012. (Kusamura, W)

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BENJAMIN B. WAGNER

United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration
PATRICK WILLIAM SNYDER, CSBN 260690
Special Assistant United States Attorney

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160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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FRESNO
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BERNADETTE A. RAMS,

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Plaintiff,
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v.
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MICHAEL J. ASTRUE,
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Commissioner of
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Social Security,
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Defendant.
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_________________________________)

CIVIL NO. 1:11-cv-02059 GSA
STIPULATION FOR EXTENSION OF
TIME AND ORDER

The parties hereby stipulate by counsel, with the Court’s approval as indicated by issuance of the

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attached Order, that Defendant shall have an extension of time of 30 days to respond to Plaintiff’s
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Motion for Summary Judgment up to and including September 21, 2012. The response is currently due
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August 22, 2012. This extension is being sought because of workload issues, including the unavoidable
transfer of assignments, a high volume of other disability matters in federal district court, federal

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employment matters, and a Ninth Circuit appellate brief. This is the Commissioner’s first extension

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request.

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

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Respectfully submitted,

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Dated: August 20, 2012

/s/ Denise Bourgeois Haley
_____________________
DENISE BOURGEOIS HALEY
(as authorized via email on August 20, 2012)
Attorney at Law
Attorney for Plaintiff

Dated: August 20, 2012

BENJAMIN B. WAGNER

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United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Patrick William Snyder
_______________________
PATRICK WILLIAM SNYDER
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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IT IS SO ORDERED.

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Dated:
i70h38

August 21, 2012

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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