Stoltzner v. Commissioner of Social Security

Filing 13

STIPULATION to Extend Briefing Schedule and ORDER signed by Magistrate Judge Erica P. Grosjean on 5/4/2017. It is hereby ordered that plaintiff may have an extension of time for Plaintiff to provide Defendant with Plaintiff's Settlement Letter Brief to and including May 2, 2017; Defendant may have an extension of time to June 6, 2017 to file her response. All other deadlines in the scheduling order are modified accordingly. (Valdez, E)

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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 ANDY D. STOLTZNER

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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ANDY D. STOLTZNER,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: 1:16-cv-01490-EPG
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE; ORDER
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TO THE HONORABLE ERICA P. GROSJEAN, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Andy D. Stoltzner (“Plaintiff”) and defendant Nancy A. Berryhill,
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 May 2, 2017; and that Defendant shall have until June 6, 2017, to provide
a response.

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As the Court is aware, after a 5 year battle with terminal stage 4 cancer

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Plaintiff’s Spouse passed away on September 30, 2016. The aftermath of this

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traumatic event on both Counsel and his 9 year old son and 7 year old daughter was

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immeasurable. Compounding the impact of this loss is the fact that Counsel’s

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spouse was a former employee at Counsel’s Law Firm and her death was far

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reaching in its impact on Counsel’s professional life as well. Due to the death, the

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subsequent holiday period, and the need to find a permanent caregiver and the

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required time to acclimate his children to that presence during his absence to meet

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his professional obligations, Counsel required the additional time to prepare and

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provide Defendant with Plaintiff’s Settlement Letter Brief.

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Counsel for plaintiff does not anticipate this extraordinary request for more

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time to become the rule and recognizes it is the extraordinary exception and

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sincerely apologizes to the court for any inconvenience this may have had upon it

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or its staff.
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DATE: May 2, 2017

LAW OFFICES OF LAWRENCE D. ROHLFING

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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff ANDY D. STOLTZNER

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Respectfully submitted,

DATE: May 2, 2017

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SANDRA R. BROWN
Acting United States Attorney
Donna L. Calvert
Regional Chief Counsel, Region IX
Social Security Administration

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*/S/- Carolyn B. Chen
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Carolyn B. Chen
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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Order

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Based on the above stipulation and good cause appearing therein, IT IS

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HEREBY ORDERED that plaintiff may have an extension of time for Plaintiff to

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provide Defendant with Plaintiff’s Settlement Letter Brief to and including May 2,

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2017; Defendant may have an extension of time to June 6, 2017 to file her

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response. All other deadlines in the scheduling order are modified accordingly.

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IT IS SO ORDERED.
Dated:

May 4, 2017

/s/
UNITED STATES MAGISTRATE JUDGE

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