Closson v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 7/10/2014 ORDERING that plaintiff may have an extension of time, to and including 7/11/2014, in which to file Plaintiff's Motion for Summary Judgment or Remand; Defendant may have an extension of time to 8/11/2014 to file her opposition, if any is forthcoming. Any reply by plaintiff will be due 8/18/2014. (Zignago, K.)

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Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

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Attorneys for Plaintiff ANGELA CLOSSON
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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ANGELA CLOSSON,
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Plaintiff,
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vs.
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CAROLYN COLVIN, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: 2:13-CV-2381 KJN
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE KENDALL J. NEWMAN, MAGISTRATE
JUDGE OF THE DISTRICT COURT:
Plaintiff Angela Closson (“Plaintiff”) and defendant Carolyn Colvin, Acting
Commissioner of Social Security (“Defendant”), through their undersigned counsel
of record, hereby stipulate, subject to the approval of the Court, to extend the time
for Plaintiff to file Plaintiff’s Motion for Summary Judgment or Remand to July
11, 2014; and that Defendant shall have until August 11, 2014, to file her

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opposition, if any is forthcoming. Any reply by plaintiff will be due August 18,

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2014.

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A second extension of time for plaintiff is needed due to a serious illness.

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Plaintiff’s Counsel’s Spouse recently began weekly chemotherapy treatment for her

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Stage IV breast cancer which metastasized initially to her liver and continues to

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spread to her lungs and spine. Counsel requires the additional time to file the Joint

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Stipulation to allow him to devote the appropriate time to assist his Spouse and his

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two elementary school aged children through this obviously stressful experience.

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Counsel sincerely apologizes to the court for any inconvenience this may have had

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upon it or its staff.

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DATE: July 8, 2014

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Respectfully submitted,
LAW OFFICES OF LAWRENCE D. ROHLFING
/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff ANGELA CLOSSON

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DATED: July 8, 2014

BENJAMIN WAGNER
United States Attorney

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*/S/- Susan L. Smith
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Susan L. Smith
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

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and including July 11, 2014, in which to file Plaintiff’s Motion for Summary

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Judgment or Remand; Defendant may have an extension of time to August 11,

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2014 to file her opposition, if any is forthcoming. Any reply by plaintiff will be

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due August 18, 2014.

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IT IS SO ORDERED.
Dated: July 10, 2014

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