Colston v. Commissioner of Social Security
Filing
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STIPULATION and ORDER for Extension of Time to File Plaintiff's Motion for Summary Judgment. The deadline by which Plaintiff shall file his summary judgment brief is extended to October 19, 2016. Defendant's responsive brief shall be filed on or before November 21, 2016, and Plaintiff may file an optional reply brief on or before December 9, 2016. Order signed by Magistrate Judge Sheila K. Oberto on 9/29/2016. (Timken, A)
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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:
jaf@forslundlaw.com
Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
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MICHAEL CHARLES COLSTON,
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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-01750-SKO
STIPULATION AND 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 October 19, 2016, for Plaintiff to file his Opening Brief, in accordance with the
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Court’s Scheduling Order. This is Plaintiff's second request for an extension. This extension is
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requested because 1) Plaintiff's counsel had health problems this summer that caused a work backlog;
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2) Plaintiff's counsel mis-calendared the due date for the Opening Brief; 3) when Plaintiff's counsel
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was working on the Opening Brief last week, she lost her work because of a computer "glitch" of
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unknown origin; and 4) Plaintiff's counsel has six briefs due in the next two weeks, one Ninth Circuit
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brief, four Opening Briefs and one Reply brief and so will not be able to immediately resume work
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on this Opening Brief.
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Colston v. Colvin
Stipulation and Order
E.D. Cal. 1-15-cv-01750-SKO
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: September 27, 2016
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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: September 26, 2016
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BENJAMIN B. WAGNER
United States Attorney
DEBORAH STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
/s/Jeffrey Chen
JEFFREY 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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Having considered Plaintiff’s amended Stipulation for Extension of Time to File Plaintiff’s
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Motion for Summary Judgment above (Doc. 17), and in view of Defendant’s lack of opposition to
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Plaintiff’s request for an extension, the Court finds that good cause has been shown to warrant
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granting the request. See Fed. R. Civ. 16(b)(4).
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Accordingly, IT IS HEREBY ORDERED that the deadline by which Plaintiff shall file his
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summary judgment brief is extended to October 19, 2016. Defendant’s responsive brief shall be filed
Colston v. Colvin
Stipulation and Order
E.D. Cal. 1-15-cv-01750-SKO
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on or before November 21, 2016, and Plaintiff may file an optional reply brief on or before December
9, 2016.
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IT IS SO ORDERED.
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Dated:
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September 29, 2016
/s/
Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE
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Colston v. Colvin
Stipulation and Order
E.D. Cal. 1-15-cv-01750-SKO
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