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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Denise Bourgeois Haley
Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
MORGANA K. SUMMERS

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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MORGANA K. SUMMERS
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Plaintiff,
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v.

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CAROLYN W. COLVIN, Acting
Commissioner of Social Security.

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Defendant.
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Case No.: 2:13-cv-01998-CMK
STIPULATION AND ORDER FOR A
SECOND EXTENSION OF TIME TO
FILE PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

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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

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respective counsel, that Plaintiff shall have a 44-day extension of time, to and

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including July 18, 2014, in which to file Plaintiff’s Motion for Summary Judgment.

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This is counsel’s second request is made at the request of Plaintiff’s counsel

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to allow additional time to fully research the issues presented. Counsel has been

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unable to complete the motion with multiple motions being due. Counsel is

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working diligently; however, she has four motions due today and while completing
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one must continue the others. Counsel makes every effort to give her full

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attention to each case and has had to continue cases because the case load has been

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extensive. Counsel is making efforts to shift cases; however, we are losing one

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associate and while another is coming, it will take time until the new associate can

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take on the additional workload. Counsel is working zealously and at maximum

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capacity and must respectfully request this last extension of time. Counsel will

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have the motion file by the above date.

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DATE: June 4, 2014

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley

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BY: _______________________
Denise Bourgeois Haley
Attorney for plaintiff Ms. Morgana K. Summers

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DATE: June 4, 2014
ANDRÉ BIROTTE JR.
United States Attorney
LEON W. WEIDMAN
Chief, Civil Division

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/s/ Timothy R. Bolin

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BY: ____________________________
Timothy R. Bolin
Special Assistant United States Attorney
Attorneys for defendant Carolyn W. Colvin
|*authorized by e-mail|

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SO ORDERED.

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Dated: June 11, 2014

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