Sanchez v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER extending time to file either a Stipulation to Remand or Opposition to Plaintiff Motion for Summary Judgment signed by Magistrate Judge Kendall J. Newman on 12/12/13. (Kaminski, H)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX,
Social Security Administration
PAUL SACHELARI, CSBN 230082
Special Assistant United States Attorney
Social Security Administration
160 Spear St., Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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DANNIE SANCHEZ,

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Plaintiff,

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v.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,

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Defendant.

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) Civil No. 2:13-cv-00786-KJN
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) STIPULATION AND PROPOSED ORDER
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) TO EXTEND TIME
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend

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the time by 45 days, to January 22, 2014, for Defendant to file either a Stipulation to Remand or her

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Opposition to Plaintiff Motion for Summary Judgment, according to the Court’s Scheduling Order

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(“Order”). This extension is requested because the parties are engaged in extended good faith

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settlement negotiations. Defendant respectfully requests additional time in order to pursue possible

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settlement.

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Stip Extend: 2:13-cv-00786-KJN

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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Date: December 9, 2013

Dellert Baird Law Offices, PLLC

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By:

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/s/ Kelsey Mackenzie Brown*
KELSEY MACKENZIE BROWN
*By email authorization

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Attorney for Plaintiff

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Date: December 9, 2013

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

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By:

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/s/ Paul Sachelari
PAUL SACHELARI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.
Dated: December 12, 2013

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Stip Extend: 2:13-cv-00786-KJN

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