Anderson v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 5/29/13 ORDERING that the requested Extension of Plaintiff's time to file a Motion for Summary Judgment is APPROVED. Plaintiff shall file his motion for Summary Judgment 7/20/2013. (Mena-Sanchez, L)

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MARK J. HANNON SBN: 107829
Attorney At Law
1114 W. Fremont St.
Stockton, California, 95203
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff

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IN THE UNITED STATES DISTRICT COURT,

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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GEORGE WAYNE ANDERSON

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Plaintiff,
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vs.
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CAROLYN COLVIN, Acting
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Commissioner of Social Security
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Defendant.
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____________________________________)

Case No. 2:12-cv-02575-EFB
STIPULATION AND [proposed]
ORDER EXTENDING PLAINTIFF’S
TIME TO FILE A MOTION FOR
SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED by and between the parties, through their respective
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undersigned attorneys, with the permission of the court as indicated below, that Plaintiff’s time to
file a motion for summary judgment is hereby extended from the present due date of May 20, 2013
through and until July 20, 2013.

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Plaintiff needs additional time to prepare the motion for summary judgment. Plaintiff’s

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counsel was waiting for the Transcript of the Administrative Proceedings to be mailed to his office,

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and discovered on May 23, 2013, for the first time, that the United States Attorney’s office no longer

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mails paper copies of the Transcript. Plaintiff’s counsel has tried to obtain the transcript from the

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court’s website but has received continual messages that the files are restricted.

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Plaintiff’s counsel is a sole practitioner and has an active case load of over one hundred
bankruptcies.

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For the above stated reasons, the parties request that the court grant the requested extension.

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This is the first request to extend Plaintiff’s deadline to file a motion for summary judgment.

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DATED: May 24, 2013

__/s/ Mark J Hannon_____
MARK J HANNON
Attorney for Plaintiff

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LUCILLE GONZALES, MEIS
Chief Counsel, Region IX

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DATED: May 24, 2013

By:_/s/ Timothy R. Bolin_______
TIMOTHY R. BOLIN
Special Assistant United States Attorney
Social Security Administration

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OF COUNSEL:
BENJAMIN B. WAGNER
UNITED STATES ATTORNEY
BOBBIE J. MONTOYA
Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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For good cause shown, the requested extension of Plaintiff’s time to file a motion

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for summary judgment in Anderson v Colvin, 2:12-cv-02575-EFB is hereby approved.

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Plaintiff shall file his motion for summary judgment by July 20, 2013.

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SO ORDERED.
DATED: May 29, 2013.