Vue v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER for an Extension of Time: that Defendant shall have a 45-day extension, or until March 7, 2017, in which to file an Opposition to Plaintiff's Opening Brief; and that all other deadlines set forth in the Case Management Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 1/19/2017. (Herman, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TIMOTHY R. BOLIN, CSBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Email: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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TOU VUE,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.
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) Case No.: 1:16-cv-00155-BAM
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary
Judgment be extended for 45 days from January 20, 2017 to March 7, 2017. This is Defendant’s
first request for an extension of time to respond to Plaintiff’s motion.
Defendant requests this extension due to her attorney’s inordinately heavy caseload in
January 2017 through February 2017, including an appellate brief before the United States Court
of Appeals for the Ninth Circuit and 30 other District Court cases, in a variety of stages, seven of
which require imminent briefing in the next three weeks. Defendant’s counsel is also assisting
an active employment case before the Equal Employment Opportunity Commission that is in the

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midst of the discovery process and requires responding to Complainant’s Request for

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Interrogatories, Admission and Production of Documents by January 23, 2017. Defendant’s

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counsel respectfully requests this additional time to respond to Plaintiff’s arguments.

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The parties further stipulate that all subsequent deadlines set forth in the Court’s

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Scheduling Order shall be extended accordingly.

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The parties stipulate in good faith, with no intent to prolong proceedings unduly.
Respectfully submitted,
Dated: January 17, 2017
/s/ Kelsey Brown*
(* As authorized via email on January 17, 2017)
KELSEY BROWN

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

Dated: January 17, 2017

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By:

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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States 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 a 45-day extension, or until March 7, 2017, in which to

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

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Management Order shall be extended accordingly.

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IT IS SO ORDERED.

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Dated:

/s/ Barbara

January 19, 2017

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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