Lee v. Commissioner of Social Security

Filing 22

STIPULATION for an Extension of Time of 8 days for Defendant's Response to Plaintiff's Motion for Summary Judgment; ORDER - that Defendant shall have an 8-day extension of time, or until December 23, 2016, in which to file an Opposition to Plaintiffs Opening Brief; and that all other deadlines set forth in the Courts Scheduling Order shall be modified accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 12/15/2016. (Herman, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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KONG PENG LEE,
Plaintiff,

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

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Defendant.

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Case No.: 1:15-cv-01859-BAM
STIPULATION FOR AN EXTENSION OF
TIME OF 8 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time of an additional 8 days to

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respond to Plaintiff’s motion for summary judgment. The current due date is December 15,

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2016. The new due date will be December 23, 2016.

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There is good cause for this request. Defendant is seeking this extension due to a car

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accident that Defendant’s counsel was in and will be taking leave to receive treatment and

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recover.

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Defendant is requesting additional time up to and including December 23, 2016, to

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complete Defendant’s response to Plaintiff’s motion for summary judgment. This request is

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made in good faith with no intention to unduly delay the proceedings.

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

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Respectfully submitted,
Date: December 15, 2016

PENA & BROMBERG, ATTORNEYS AT LAW

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s/ Jonathan O. Pena by C.Chen*
(As authorized by e-mail on 12/15/2016)
JONATHAN O. PENA
Attorneys for Plaintiff

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Date: December 15, 2016

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PHILLIP A. TALBERT
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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

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ORDERED that Defendant shall have an 8-day extension of time, or until December 23, 2016, in

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which to file an Opposition to Plaintiff’s Opening Brief; and that all other deadlines set forth in

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the Court’s Scheduling Order shall be modified accordingly.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

December 15, 2016

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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