Telnas v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER GRANTING Plaintiff an extension of time to provide Defendant with Plaintiff's Settlement Letter Brief to, and including, December 2, 2016; Defendant may have an extension of time to January 6, 2017, to file her response. Order signed by Magistrate Judge Erica P. Grosjean on 12/5/2016. (Rooney, M)

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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]

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Attorneys for Plaintiff SHERRI RENEE TELNAS
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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SHERRI RENEE TELNAS,
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Plaintiff,
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vs.
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CAROLYN COLVIN, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: 1:16-cv-00583-EPG
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE ERICA P. GROSJEAN, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Sherri Renee Telnas (“Plaintiff”) and defendant Carolyn Colvin,
Acting Commissioner of Social Security (“Defendant”), through their undersigned
counsel of record, hereby stipulate, pursuant to the Court’s Scheduling Order, to
extend the time for Plaintiff to provide Defendant with Plaintiff’s Settlement Letter
Brief to December 2, 2016; and that Defendant shall have until January 6, 2017, to
provide a response.

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This Court is aware that Counsel’s Spouse battled Stage IV breast cancer

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which metastasized initially to her liver and continued to progress with tumors in her

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lungs, spine and brain. After exhausting all known chemotherapy treatments over

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18 months ago and surviving on willful determination and profound faith alone

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Counsel’s wife has succumbed to her illness. On September 30, 2016 Counsel

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gently held his wife as she relinquished her fight and passed away. Counsel

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required time to deal with providing the appropriate respect to his spouse and to

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assist his two elementary school age children return to a normal routine.

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Counsel sincerely apologizes to the court for any inconvenience this may
have had upon it or its staff.

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DATE: December 2, 2016

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Respectfully submitted,
LAW OFFICES OF LAWRENCE D. ROHLFING
/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff SHERRI RENEE TELNAS

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DATE: December 2, 2016
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BENJAMIN WAGNER
United States Attorney
Donna L. Calvert
Regional Chief Counsel, Region IX
Social Security Administration

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*/S/- Marcelo N. Illarmo
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Marcelo N. Illarmo
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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

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Plaintiff to provide Defendant with Plaintiff’s Settlement Letter Brief to and

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including December 2, 2016; Defendant may have an extension of time to January

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6, 2017 to file her response.

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IT IS SO ORDERED.
Dated:

December 5, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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