Jackson v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 2/6/14 ORDERING that the time for Defendant to respond to Plaintiff's 20 MOTION for SUMMARY JUDGMENT is EXTENDED for 30 days until 3/7/2014. The parties further stipulate that the remaining dates in the Court's Scheduling Order shall be modified accordingly. (Mena-Sanchez, L)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
160 Spear Street, Suite 800
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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DEBRA ANN JACKSON,

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Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

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) Case No.: 2:13-cv-01097-CKD
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) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that the time for Defendant to respond to Plaintiff’s Motion for Summary

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Judgment be extended for 30 days until March 7, 2014. This is Defendant’s first request for an

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extension of time to respond to Plaintiff’s motion. Defense counsel was reassigned this case

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from another attorney and needs additional time to further review the file and prepare a response

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in this matter due to a heavy workload, despite due diligence.

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/////

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The parties further stipulate that the remaining dates in the Court’s Scheduling Order
shall be modified accordingly.
Defense counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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LAW OFFICE OF RICHARD WHITAKER

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Dated: February 5, 2014

/s/ Richard Allen Whitaker*___________
(*as authorized via email on 2/5/14)
RICHARD ALLEN WHITAKER
Attorney for Plaintiff

Dated: February 5, 2014

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/ Lynn M. Harada
LYNN M. HARADA
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER:

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APPROVED AND SO ORDERED:

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Dated: February 6, 2014

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE