Haverlock v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER 22 for extension of time and vacate hearing signed by Magistrate Judge Dale A. Drozd on 4/28/2013. Defendant may respond to plaintiff's 14 Motion to Augument the Record by 5/13/2013 when Cross-Motion or Opposition is due. In addition, parties stipulat that their Motions my be heard without oral argument. The 5/31/2013 Motion hearing is VACATED. (Marciel, M)

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

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ARMAND D. ROTH
Special Assistant United States Attorney
California Bar No. 214624
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Fax: [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

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Laura Faye Haverlock,

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Plaintiff,

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v.
Michael J. Astrue,
Commissioner of Social Security,

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Defendant.

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No. 12-cv-02393-DAD

STIPULATION AND ORDER
EXTENDING TIME TO FILE
OPPOSITION TO PLAINTIFF’S
MOTION TO AUGMENT THE
RECORD AND VACATING
HEARING ON THE MOTION

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On April 11, 2013, Plaintiff filed a Motion for Summary Judgment or Remand
and, at the same time, filed a Motion to Augment the Certified Administrative Record.

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IT IS HEREBY STIPULATED by the parties, through their undersigned

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attorneys, and with the approval of this Court, that Defendant may respond to Plaintiff’s

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Motion to Augment the Record by May 13, 2013, when Defendant’s Cross-Motion or

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Opposition to Plaintiff’s Motion for Summary Judgment or Remand is due. This request

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is presented to allow Defendant to better respond to Plaintiff’s simultaneous filing of two

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motions and due to Defendant’s heavy case load.1
In addition, the parties stipulate, subject to the approval of this Court, that their

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motions may be heard without oral argument and respectfully request that the Court

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vacate the hearing set forth May 31, 2013.
Respectfully submitted on April 23, 2013,

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By: /s/ Andrew T. Koenig
ANDREW T. KOENIG
Attorney for Plaintiff
(by email authorization)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX,
Social Security Administration
By: /s/ Armand Roth
ARMAND ROTH
Special Assistant United States Attorney

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED

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DATED: April 28, 2013

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Dad1.socsec
Haverlock2393.stipord.ext.opp

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Defendant may need to request an extension for filing his Cross-Motion or Opposition,
but is attempting to avoid doing so by consolidating his responses in the present case.

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