Agueda Valencia vs Commissioner of Social Security

Filing 15

STIPULATION and ORDER for a First Extension of Time for Defendant to File Her Motion for Summary Judgment: that Defendant shall have an extension of time, up to and including July 6, 2015, in which to file a cross motion for summary judgment. All other deadlines set forth in the August 28, 2014 Case Management Order are modified accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 6/5/2015. (Herman, H)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
JEFFREY CHEN, CSBN 260516
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [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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AGUEDA VALENCIA,

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Plaintiff,

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v.

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

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Civil No. 1:14-cv-01330-BAM
STIPULATION AND ORDER FOR A
FIRST EXTENSION OF TIME FOR
DEFENDANT TO FILE HER MOTION
FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and

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with the approval of the Court, that Defendant shall have a second extension of time of 30 days

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to file her motion for summary judgment. Defendant respectfully requests this additional time

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because he has a very a heavy workload despite due diligence.

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Stip. to Extend Def.’s MSJ
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The new due date for Defendant’s motion for summary judgment will be Monday, July 6,

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2015.

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Respectfully submitted,

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Date: June 4, 2015

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NEWEL LAW
By:

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Date: June 4, 2015

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/ Melissa Newel*
MELISSA NEWEL
* By email authorization on June 2, 2015
Attorney for Plaintiff

/s/ Jeffrey Chen
JEFFREY CHEN
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER
Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY

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ORDERED, that Defendant shall have an extension of time, up to and including July 6, 2015, in

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which to file a cross motion for summary judgment. All other deadlines set forth in the August

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28, 2014 Case Management Order are modified accordingly.

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IT IS SO ORDERED.

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Dated:

/s/ Barbara

June 5, 2015

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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