Perry v. Commissioner of Social Security

Filing 18

Stipulation and Order for a first extension of time for Defendant to respond to Plaintiff's Motion for Summary Judgment, signed by Magistrate Judge Sandra M. Snyder on 3/20/2015. (Response due by 5/7/2015) (Rosales, O)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT, SBN IL 6191786
Regional Chief Counsel, Region IX
Social Security Administration
HENRY L. CHI, CSBN 265009
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
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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PATRICIA IRENE PERRY,

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Plaintiff,
v.

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CAROLYN W. COLVIN,

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Acting Commissioner of Social Security,

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Defendant.

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CIVIL NO. 1:14-CV-00825-SMS
STIPULATION AND ORDER FOR A
FIRST EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

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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 first extension of time of 45 days to respond to
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Plaintiff’s opening brief. There is good cause for this extension because of Assistant Regional
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Counsel Henry Chi’s workload. Despite his diligent efforts, competing deadlines necessitate an
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extension. Additionally, Defendant needs additional time to respond to Plaintiff’s arguments.
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Perry
Stip. and Proposed Order for Extension - 1:14-cv-00825-SMS

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Given these factors, Defendant respectfully requests an extension and Plaintiff also consents to

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this extension.

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The current due date is March 23, 2015. The new due date will be May 7, 2015. 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: March 17, 2015

/s/ Jacqueline Anna Forslund
(by email authorization on March 17, 2015)
Jacqueline Anna Forslund
Attorney for Plaintiff

Dated: March 19, 2015

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/ Henry L. Chi
Henry L. Chi
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED.

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DATED: 3/20/2015
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/s/ SANDRA M. SNYDER
UNITED STATES MAGISTRATE JUDGE

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Perry
Stip. and Proposed Order for Extension - 1:14-cv-00825-SMS