Clamp v. Commissioner of Social Security

Filing 11

STIPULATION and ORDER GRANTING the parties' request for an extension of time, to and including August 30, 2016, for Plaintiff to provide Defendant with Plaintiff's Settlement Letter Brief; Defendant may have an extension of time to October 4, 2016, to provide a response, with all other dates as set forth in the Case Management Order adjusted accordingly. Order signed by Magistrate Judge Sandra M. Snyder on 9/6/2016. (Rooney, M)

1
2
3
4

Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

5
Attorneys for Plaintiff MICHAEL J. CLAMP
6
7
UNITED STATES DISTRICT COURT
8
EASTERN DISTRICT OF CALIFORNIA

9
10

MICHAEL J. CLAMP,
11
Plaintiff,
12
vs.
13
CAROLYN COLVIN, Acting
14
Commissioner of Social Security,
15
Defendant
16

) Case No.: 2:16-CV-00248-SMS
)
) STIPULATION TO EXTEND
) BRIEFING SCHEDULE; ORDER
)
)
)
)
)
)
)
)

17
18
19
20
21
22
23
24
25
26
27
28

TO THE HONORABLE SANDRA M. SNYDER, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Michael J. Clamp (“Plaintiff”) and defendant Carolyn Colvin,
Acting Commissioner of Social Security (“Defendant”), through their undersigned
counsel of record, hereby stipulate, subject to the approval of the Court, to extend
the time for Plaintiff to provide Defendant with Plaintiff’s Settlement Letter Brief
to August 30, 2016; and that Defendant shall have until October 4, 2016, to
provide a response, all other dates as set forth in the Case Management Order are
adjusted accordingly.

-1-

1

An extension of time for plaintiff is needed in order to properly address the

2

issues within the administrative record in this matter as well as the demands arising

3

from complications related to Counsel Spouse’s terminal illness which has

4

unexpectedly worsened in the last few weeks. Subsequent to a surgical procedure

5

on July 6, 2016 to remove tumors in the spine/hip as a result of stage 4 breast

6

cancer, Counsel’s spouse was not discharged until July 9, 2016 and then Counsel’s

7

spouse was re-admitted to the hospital for 5 days on July 15, 2016 due to

8

complications arising from the July 6th surgery. Counsel’s spouse was also

9

recently admitted on August 1, 2016 and then discharged on August 5, 2016, to

10
11
12

provide treatment for intractable pain related to the terminal illness.
Counsel sincerely apologizes to the court for any inconvenience this may
have had upon it or its staff.

13
14
DATE: August 30, 2016

Respectfully submitted,

15
LAW OFFICES OF LAWRENCE D. ROHLFING
16

/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff MICHAEL J. CLAMP

17
18
19
DATED: August 30, 2016
20

PHILLIP A. TALBERT
Acting United States Attorney

21
22
23
24
25
26
27
28

*/S/- Chantal R. Jenkins
_________________________________
Chantal R. Jenkins
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]
-2-

1

IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

2

and including August 30, 2016, for Plaintiff to provide Defendant with Plaintiff’s

3

Settlement Letter Brief; Defendant may have an extension of time to October 4,

4

2016 to provide a response, all other dates as set forth in the Case Management

5

Order are adjusted accordingly.

6
7
8
9
10

IT IS SO ORDERED.
Dated:

September 6, 2016

/s/ Sandra M. Snyder
UNITED STATES MAGISTRATE JUDGE

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-3-