Zamora v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER 17 for an Extension of Time to Serve Plaintiff's Opening Brief, signed by Magistrate Judge Jennifer L. Thurston on 1/8/2015. (Hall, S)

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JONATHAN O. PENA, SBN#278044
Law Office of Jonathan Pena
333 W. Shaw Ave., Ste. 102
Fresno, CA 93722
Ph: 559-412-5390, Fax: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Plaintiff,

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ROBERT ZAMORA,

vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

Case No.: 1:14-cv-00197-JLT
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME TO SERVE
PLAINTIFF’S OPENING BRIEF
(Doc. 17)

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that the time for serving Plaintiff’s OPENING BRIEF be extended from

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January 7, 2015 to February 21, 2015. This is Plaintiff’s first request for an extension by

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stipulation of the parties to submit Plaintiff’s Opening Brief. This is Plaintiff’s second request

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for an extension by stipulation of the parties in this matter. Due to reduced staff and office
hours, Plaintiff’s Counsel requests additional time to research and complete review of the
administrative record. Counsel apologizes to the Court and all parties involved for any
inconvenience caused by this delay.

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Dated: January 6, 2015

Respectfully submitted,
/s/__Jonathan Omar Pena__
JONATHAN OMAR PENA
Attorney for Plaintiff

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Dated: January 6, 2015

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

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By:

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(As authorized via email on 1/6/15)
/s/_____________________
JEFFREY T. CHEN
Office of the General Counsel/SSA
Attorneys for Defendant

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ORDER

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Based upon the stipulation of counsel, the Court ORDERS:
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Plaintiff SHALL file his opening brief no later than February 21, 2015;

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No further extensions of time will be granted absent a showing of exceptional

good cause.

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IT IS SO ORDERED.
Dated:

January 8, 2015

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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