Keller v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER EXTENDING BRIEFING SCHEDULE signed by Magistrate Judge Carolyn K. Delaney on 7/10/2013: The filing deadline for plaintiff's opening brief is extended to 8/23/2013. Defendant's opposition is due by 9/23/2013. Plaintiff's reply, if any, is due by 9/30/2013. (Owen, K)

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Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

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Attorneys for Plaintiff LYNNE KELLER
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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LYNNE KELLER
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) Case No.: 2:13-CV-221-CKD
)
Plaintiff,
) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
vs.
)
)
MICHAEL J. ASTRUE, Commissioner )
)
of Social Security,
)
)
Defendant
)
)

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TO THE HONORABLE CAROLYN K. DELANEY, MAGISTRATE
JUDGE OF THE DISTRICT COURT:
Plaintiff Lynne Keller (“Plaintiff”) and defendant Michael Astrue,
Commissioner of Social Security (“Defendant”), through their undersigned counsel
of record, hereby stipulate, subject to the approval of the Court, to extend the time
for Plaintiff to file Plaintiff’s Opening Brief to August 23, 2013; and that
Defendant shall have until September 23, 2013, to file his opposition, if any is
forthcoming. Any reply by plaintiff will be due September 30, 2013.

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An extension of time for plaintiff is needed due to a serious illness in

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Counsel’s family. Counsel Spouse receives chemotherapy treatment for her Stage

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IV breast cancer which metastasized initially to her liver and continues to spread to

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her lungs and spine. Counsel requires the additional time to file the Joint Stipulation

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to allow him to devote the appropriate time to assist his Spouse and his two

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kindergarten and pre-school aged children through this obviously stressful

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experience. Counsel sincerely apologizes to the court for any inconvenience this

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may have had upon it or its staff.

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DATE: July 8, 2013

Respectfully submitted,

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LAW OFFICES OF LAWRENCE D. ROHLFING
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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff LYNNE KELLER

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DATE: July 8, 2013
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BENJAMIN WAGNER
United States Attorney

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*/S/- Jean M. Turk
_________________________________
Jean M. Turk
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

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and including August 23, 2013, in which to file Plaintiff’s Opening Brief;

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Defendant may have an extension of time to September 23, 2013 to consider the

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contentions raised in Plaintiff’s Opening Brief, and file any opposition if

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necessary. Any reply by plaintiff will be due September 30, 2013.

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IT IS SO ORDERED.
Dated: July 10, 2013
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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