Overend v. Commissioner of Social Security

Filing 20

STIPULATION for an Extension of Time of 45 Days for Defendant's Response to Plaintiff's Motion for Summary Judgment; ORDER re 19 signed by Magistrate Judge Gary S. Austin on 6/12/2015. (Martinez, A)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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

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Case No.: 1:14-cv-01309-GSA
STIPULATION FOR AN EXTENSION OF
TIME OF 45 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT; ORDER
(ECF No. 19)

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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 an extension of time of an additional 45 days to

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respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by

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Defendant. The current due date is June 17, 2015. The new due date will be August 3, 2015.

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There is good cause for this request. Defendant is seeking this extension due to

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Defendant’s counsel’s full workload and pre-approved leave in June and July. Defense counsel

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was also absent from the office briefly after being hit in a car accident recently. Defense counsel

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is requesting additional time up to fully review the administrative record and research the issues

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presented by Plaintiff’s motion for summary judgment.

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Stipulation and Order for an Extension of Time; 1:14-cv-01309-GSA

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

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Respectfully submitted,
Date: June 11, 2015

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s/ Jacqueline A. Forslund by C.Chen*
(As authorized by e-mail on 6/11/2015)
JACQUELINE A. FORSLUND
Attorneys for Plaintiff

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JACQUELINE A. FORSLUND, ATTORNEY AT
LAW

Date: June 11, 2015

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BENJAMIN B. WAGNER
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER
Based on the stipulation between the parties, Defendant may have an extension of time to
file her opposition brief. Defendant shall file her opposition brief no later than August 3, 2015.
Plaintiff may file her reply brief no later than August 18, 2015.

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IT IS SO ORDERED.
Dated:

June 12, 2015

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Order for an Extension of Time; 1:14-cv-01309-GSA

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