Klev v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 1/17/12 ORDERING that the Defendant shall have a first extension of time of 30 days to file his cross-motion for summary judgment. The new due date will be 2/8/12.The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. (Becknal, R)

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BENJAMIN B. WAGNER
United States Attorney
DONNA CALVERT
Acting Regional Chief Counsel, Region IX
BRENDA M. PULLIN
Special Assistant United States Attorney
Social Security Administration
333 Market Street, Suite 1500
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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RHONDA KLEV,

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Plaintiff,
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v.
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MICHAEL J. ASTRUE,
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Commissioner of Social Security,
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Defendant.
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_________________________________)

CASE NO. 2:11-CV-00863-GGH
STIPULATION AND ORDER FOR FIRST
EXTENSION OF TIME TO FILE
DEFENDANT’S CROSS-MOTION

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The parties hereby stipulate through counsel, with the Court’s approval as indicated by issuance

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of the attached Order, that Defendant shall have a first extension of time of 30 days to file his

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cross-motion for summary judgment.

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The extension is being sought due to defendant’s counsel’s heavy workload during the past

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month combined with her long-scheduled holiday leave and cross-country travel. In addition, reduced

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staffing makes reassignment of the case to another attorney an impossibility, as no other attorney is

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available to take on additional duties. Several senior attorneys have recently left the regional counsel’s

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office and cannot be replaced due to the hiring freeze.

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Given these constraints, the Commissioner respectfully requests 30 additional days in which to

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complete the Commissioner’s cross-motion for summary judgment. The new due date will be

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February 8, 2012.

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

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Respectfully submitted,
Dated: January 11, 2012

/s/ Bess M. Brewer
(As authorized via e-mail)
BESS M. BREWER
Attorney for Plaintiff

Dated: January 9, 2012

BENJAMIN B. WAGNER
United States Attorney

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/s/ Brenda M. Pullin
BRENDA M. PULLIN
Special Assistant U.S. Attorney

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IT IS SO ORDERED:

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Dated: January 17, 2012
/s/ Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE

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