Rios v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER, signed by Magistrate Judge Stanley A. Boone on 5/29/2015. FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFFS MOTION FOR SUMMARY JUDGMENT (FIRST REQUEST BY DEFENDANT) (Kusamura, W)

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BENJAMIN WAGNER CSBN 163581
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration
MARLA K. LETELLIER, CSBN 234969
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
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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JEANETTE RIOS,
Plaintiff,
vs.

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CAROLYN W. COLVIN,
Acting Commissioner of
Social Security,

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Defendant.

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CIVIL NO. 1:14-CV-01346-SAB
STIPULATION FOR EXTENSION OF
TIME FOR DEFENDANT TO
RESPOND TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT (FIRST
REQUEST BY DEFENDANT)

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IT IS HEREBY STIPULATED, by and between the undersigned attorneys, subject to the

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approval of the Court, that Defendant shall have a 30 day extension, from May 29, 2015 to June 29,

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2015 in which to file her Opposition to Plaintiff’s Opening Brief or otherwise respond to Plaintiff’s

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motion.

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Stip for EOT, 1:14-CV-01346-SAB

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This request is the result of a heavy workload for counsel responsible for briefing this case.
Additionally, counsel was out of the office unexpectedly last week to care for a sick child and continues
to work through her backlog of work. This request is not meant to cause intentional delay.

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Respectfully submitted,

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BENJAMIN WAGNER
United States Attorney

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Dated: May 28, 2015

By: /s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant United States Attorney
Attorneys for Defendant

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DELLERT BAIRD LAW OFFICES, PLLC

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Dated: May 28, 2015

By: /s/ Kelsey M. Brown
KELSEY M. BROWN
Attorney for Plaintiff
(as approved by email on May 28, 2015)

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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IT IS SO ORDERED.

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Dated:

May 29, 2015
UNITED STATES MAGISTRATE JUDGE

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Stip for EOT, 1:14-CV-01346-SAB

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