Campos v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER for Extension of Time: Defendant's first request for an extension of time, by 4/18/2015, to respond to Plaintiff's motion. signed by Magistrate Judge Barbara A. McAuliffe on 3/31/2015. (Herman, H)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
KEVIN G. GILL – CSBN 226819
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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FRESNO DIVISION
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AUSENCIO CAMPOS,
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Plaintiff,
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vs.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,
Defendant.

) Case No.: 1:14-cv-00802-BAM
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective
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counsel of record, that Defendant shall have a 30-day extension of time, to and including April
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18, 2015, in to file her responsive brief. This is Defendant’s first request for an extension of time
to respond to Plaintiff’s motion. Defendant requests this extension because he is currently

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responding to discovery, conducting and defending depositions, and preparing witnesses and
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arguments for an upcoming Merit Systems Protection Board hearing. As a result, Defendant
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needs additional time to respond to the issues raised in Plaintiff’s portion of the joint stipulation.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly. Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: March 26, 2015

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LAWRENCE D. ROHLFING
By:

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/s/ Vijay J. Patel *
VIJAY J. PATEL
(* As authorized via email on March 26, 2015)
Attorney for plaintiff Mr. Ausencio Campos

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Dated: March 26, 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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/s/ Kevin G. Gill
KEVIN G. GILL
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER
Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY
ORDERED, that Defendant shall have an extension of time, up to and including April 18, 2015,

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in which to file a response to Plaintiff’s opening brief. All other deadlines set forth in the June 2,

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2014 Case Management Order are modified accordingly.

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IT IS SO ORDERED.

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Dated:

/s/ Barbara

March 31, 2015

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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