Klev v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 2/21/2012 GRANTING a 30-Day Extension of time for Defendant to file a Cross-Motion for Summary Judgment. Motion to be filed by 3/9/2012. (Michel, G)
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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: (415) 977-8975
Facsimile: (415) 744-0134
E-Mail:Brenda.Pullin@ssa.gov
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 SECOND
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 second extension of time of 30 days, nunc pro tunc, to
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file his cross-motion for summary judgment.
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The extension is being sought due to defendant’s counsel’s litigation workload during the past
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month combined with the length of the administrative record in this case. In addition, defendant’s
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counsel inadvertently miscalendered the previous extension by a week. Unfortunately, reduced staffing
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makes reassignment of the case to another attorney an impossibility, as no other attorney is available to
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take on additional duties. Several senior attorneys have recently left the regional counsel’s office and
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cannot be replaced due to the hiring freeze.
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 March 9,
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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: February 16, 2012
/s/ Bess M. Brewer
(As authorized via e-mail)
BESS M. BREWER
Attorney for Plaintiff
Dated: February 15, 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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No further extensions.
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Dated: February 21, 2012
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/s/Gregory G. Hollows
____________________________________
United States Magistrate Judge
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