Robert David Tellez v. Commissioner of Social Security

Filing 12

Stipulation and Order for extension of time to file Plaintiff's Motion for Summary Judgment, signed by Magistrate Judge Sandra M. Snyder on 8/5/2016. (Opening Brief Deadline: 9/3/2016) (Rosales, O)

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JACQUELINE A. FORSLUND
Forslund Law, LLC
CSBN 154575
P.O. Box 4476
Sunriver, OR 97707
Telephone:
541-419-0074
Fax:
541-593-4452
Email:
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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ROBERT DAVID TELLEZ,

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Plaintiff
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v.
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CAROLYN W. COLVIN,
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Acting Comm’r of Social Security,
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Defendant
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____________________________________)

Case No. 1:15-cv-01693-SMS
STIPULATION AND PROPOSED
ORDER FOR EXTENSION OF TIME
TO FILE PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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

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the time 30 Days to September 3, 2016, for Plaintiff to file his Opening Brief, in accordance with the

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Court’s Scheduling Order. This is Plaintiff’s first request for an extension. This extension is

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requested because Plaintiff’s counsel has several Ninth Circuit briefs due in the next couple of weeks

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and is experiencing a heavier than usual work load.
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Tellez v. Colvin

Stipulation and Proposed Order

E.D. Cal. 1-15-cv-01693-SMS

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

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accordingly.

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Respectfully submitted,

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Date: August 4, 2016

JACQUELINE A. FORSLUND
Attorney at Law

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/s/Jacqueline A. Forslund
JACQUELINE A. FORSLUND

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Attorney for Plaintiff

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Date: August 4, 2016

PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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/s/Carolyn Chen
CAROLYN CHEN
Special Assistant United States Attorney
*By email authorization

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Attorney for Defendant
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ORDER

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IT IS SO ORDERED.
Dated:

August 5, 2016

/s/ Sandra M. Snyder
UNITED STATES MAGISTRATE JUDGE

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Tellez v. Colvin

Stipulation and Proposed Order

E.D. Cal. 1-15-cv-01693-SMS