Allen v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER 21 for extension of time signed by Magistrate Judge Edmund F. Brennan on 10/26/2015. Commissioner's Cross-Motion for Summary Judgment is now due 12/14/2015. (Marciel, M)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
ANNABELLE J. YANG
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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TOMMIE LEE ALLEN,

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

Case No. 2:13-cv-1366-EFB
STIPULATION AND ORDER TO
EXTEND TIME

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The parties hereby stipulate by counsel, with the Court’s approval as indicated by

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issuance of the attached Order, that Defendant shall have a FIRST extension of time of 35

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days, from November 9, 2015, to December 14, 2015, to file her Cross-Motion for Summary

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Judgment.

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There is good cause for this extension as Defendant’s counsel has 11 District Court

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briefs, one Ninth Circuit appellate brief, and court-ordered deadlines in a matter before the Equal

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Employment Opportunity Commission over the next six weeks. Additionally, Defendant’s

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counsel has scheduled leave that necessitates this extension. Defendant apologizes to the Court

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for this delay and hereby requests to extend the schedule in this matter. The parties further
stipulate that the Court’s Scheduling Order shall be modified accordingly.
Case No. 2:13-cv-01366-EFB

Respectfully submitted,

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Dated: October 26, 2015

/s/ Shellie Lott*
SHELLIE LOTT
*as authorized via email on Oct. 22, 2015
Attorney for Plaintiff

Dated: October 26, 2015

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By:
/s/ Annabelle J. Yang
ANNABELLE J. YANG
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.
DATED: October 26, 2015.

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Case No. 2:13-cv-01366-EFB