Jurado v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 1/11/2012 EXTENDING time to file Defendant's Cross-Motion for Summary Judgment. Motion to be filed by 2/10/2012. (Michel, G)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT, IL SBN 6191786
Acting Regional Chief Counsel, Region IX
Social Security Administration
DAVID W. LERCH, CA SBN 229411
Special Assistant United States Attorney
333 Market Street, Suite 1500
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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ALBERT JURADO,

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

CIVIL NO. 2:11-cv-1489-CMK
STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO FILE
DEFENDANT’S CROSS-MOTION FOR
SUMMARY JUDGMENT

The parties hereby stipulate by counsel, with the Court’s approval as indicated by issuance of the
attached Order, that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s
motion for summary judgment.
Counsel for Defendant respectfully requests an extension of time due to his workload, which
includes other district court briefs, as well as substantive non-litigation matters.
The current due date is January 11, 2012. The new due date will be February 10, 2012.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

Respectfully submitted,

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Dated: January 10, 2012

/s/ Ann Cerney
(As authorized via email)
Ann Cerney
Attorney for Plaintiff

Dated: January 9, 2012

BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration

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/s/ David Lerch
DAVID LERCH
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED.

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DATED: January 11, 2012
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CRAIG M. KELLISON
UNITED STATES MAGISTRATE JUDGE

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2 - Stip & Order Extending Def's Time