Martin v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER signed by Magistrate Judge Dale A. Drozd on 2/27/2015 ORDERING the defendant to respond to the 15 Motion for Summary Judgment by 4/6/2015; MODIFYING the Court's Scheduling Order accordingly. (Michel, G.)

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BENJAMIN B. WAGNER
United States Attorney
DONNA CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
JACOB M. MIKOW, CSBN 238045
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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LOIS MARTIN,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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) No. 2:13-cv-02671-DAD
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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 responding to Plaintiff’s Motion for Summary Judgment be

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extended from March 6, 2015 to April 6, 2015. This is Defendant’s second request for an

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extension of time to respond to Plaintiff’s motion. Assistant Regional Counsel In Seon Jeong

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was assigned to this case and has diligently attempted to complete Defendant’s responsive brief

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in a timely matter. However, the undersigned counsel for Defendant seeks this extension due to

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the press of workload including a Ninth Circuit brief and high volume of other disability matters.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

Stip. & Prop. Order for Ext.; 2:13-cv-02671-DAD

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Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,
/s/ Jesse S. Kaplan_____
(As authorized via email on 2/26/2015)
JESSE S. KAPLAN
Attorney for Plaintiff

Dated: February 26, 2015

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Dated: February 26, 2015

BENJAMIN B. WAGNER
United States Attorney
DONNA CALVERT
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Jacob M. Mikow
JACOB M. MIKOW
Special Assistant United States Attorney
Attorneys for Defendant

OF COUNSEL:

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In Seon Jeong
Assistant Regional Counsel

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ORDER
Pursuant to the parties’ stipulation, IT IS SO ORDERED.
Dated: February 27, 2015

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Ddad1\orders.soc sec\martin2671.stip.eot3.ord.docx

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Stip. & Prop. Order for Ext.; 2:13-cv-02671-DAD

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