Freeman v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/12/14 ORDERING that the time for Defendant to respond to Plaintiff's Motion for Summary Judgment be extended for 30 days until March 28, 2014. (Becknal, R)

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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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TONYA L. FREEMAN,

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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-01423-CMK
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) STIPULATION AND 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 28, 2014. This is Defendant’s first request for an

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extension of time to respond to Plaintiff’s motion. Defense counsel needs the additional time to

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further review the file and prepare a response in this matter due to a heavy workload, despite due

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diligence.

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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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Dated: February 26, 2014

/s/ Jesse S. Kaplan* _____________
(*as authorized via email on 2/26/14)
JESSE S. KAPLAN
Attorney for Plaintiff

Dated: February 26, 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

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Attorneys for Defendant

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ORDER:

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APPROVED AND SO ORDERED:

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Dated: March 12, 2014