Summers v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 6/11/2014 ORDERING that Plaintiff shall have a 44-day extension of time, to and including 7/18/2014, in which to file Plaintiff's Motion for Summary Judgment. (Zignago, K.)

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1 2 3 4 5 Denise Bourgeois Haley Attorney at Law: 143709 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)868-5886 Fax: (562)868-5491 E-Mail: Attorneys for Plaintiff MORGANA K. SUMMERS 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 MORGANA K. SUMMERS 12 Plaintiff, 13 v. 14 CAROLYN W. COLVIN, Acting Commissioner of Social Security. 15 Defendant. 16 ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:13-cv-01998-CMK STIPULATION AND ORDER FOR A SECOND EXTENSION OF TIME TO FILE PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 17 18 19 20 TO THE HONORABLE CRAIG M. KELLISON, UNITED STATES DISTRICT COURT, MAGISTRATE JUDGE OF THE DISTRICT COURT: IT IS HEREBY STIPULATED by and between the parties, through their 21 respective counsel, that Plaintiff shall have a 44-day extension of time, to and 22 including July 18, 2014, in which to file Plaintiff’s Motion for Summary Judgment. 23 This is counsel’s second request is made at the request of Plaintiff’s counsel 24 to allow additional time to fully research the issues presented. Counsel has been 25 unable to complete the motion with multiple motions being due. Counsel is 26 working diligently; however, she has four motions due today and while completing -1- 1 one must continue the others. Counsel makes every effort to give her full 2 attention to each case and has had to continue cases because the case load has been 3 extensive. Counsel is making efforts to shift cases; however, we are losing one 4 associate and while another is coming, it will take time until the new associate can 5 take on the additional workload. Counsel is working zealously and at maximum 6 capacity and must respectfully request this last extension of time. Counsel will 7 have the motion file by the above date. 8 DATE: June 4, 2014 Respectfully submitted, LAWRENCE D. ROHLFING 9 /s/ Denise Bourgeois Haley 10 BY: _______________________ Denise Bourgeois Haley Attorney for plaintiff Ms. Morgana K. Summers 11 12 13 14 DATE: June 4, 2014 ANDRÉ BIROTTE JR. United States Attorney LEON W. WEIDMAN Chief, Civil Division 15 16 /s/ Timothy R. Bolin 17 BY: ____________________________ Timothy R. Bolin Special Assistant United States Attorney Attorneys for defendant Carolyn W. Colvin |*authorized by e-mail| 18 19 20 21 SO ORDERED. 22 Dated: June 11, 2014 23 24 25 26 -2-

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