Simon v. Commissioner of Social Security

Filing 20

Stipulation and Order for a first extension of time for Defendant to file her Motion for Summary Judgment, signed by Magistrate Judge Erica P. Grosjean on 7/6/2016. (Opposition/Motion for Summary Judgment Deadline: 8/4/2016) (Rosales, O)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting 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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YVONNE SIMON,

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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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No. 1:15-cv-01239-EPG
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 first extension of time of 30 days to

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

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because of a heavy accumulated workload as a result of a two week absence from the office in

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Taiwan after the passing of the undersigned’s grandfather.

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The new due date for Defendant’s motion for summary judgment will be Thursday,
August 4, 2016.

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Respectfully submitted,

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Date: July 4, 2016

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DELLERT BAIRD LAW OFFICES, PLLC
By:

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Date: July 4, 2016

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/ Kelsey Brown*
KELSEY MACKENZIE BROWN
* By email authorization on July 4, 2016
Attorney for Plaintiff

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

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ORDER

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Pursuant to the parties’ stipulation, Defendant shall file her Opposition/Motion for

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Summary Judgment on August 4, 2016. Any reply shall be filed within 15 days of the filing of

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Defendant’s pleading.

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IT IS SO ORDERED.

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Dated:

July 6, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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