Perry v. Commissioner of Social Security

Filing 20

Stipulation and Order for a second extension of time for Defendant to respond to Plaintiff's Motion for Summary Judgment, signed by Magistrate Judge Sandra M. Snyder on 5/5/2015. (Response due by 6/22/2015) (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
SECOND 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
counsel of record, that Defendant shall have a second extension of time of 45 days to respond to
Plaintiff’s opening brief. Defendant apologizes for seeking a second extension and expects to file

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the response by the extended deadline. There is good cause for this extension because

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

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Defendant’s counsel has competing deadlines that necessitate immediate attention – including
other district court matters, employment matters, and an oral argument. Given these factors,
Defendant respectfully requests an extension and Plaintiff also consents to this extension.
The current due date is May 7, 2015. The new due date will be June 22, 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: May 4, 2015

/s/ Jacqueline Anna Forslund
(by email authorization on May 4, 2015)
Jacqueline Anna Forslund
Attorney for Plaintiff

Dated: May 4, 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

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APPROVED AND SO ORDERED.
DATED: 5/5/2015

/s/ SANDRA M. SNYDER
UNITED STATES MAGISTRATE JUDGE

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