Gambrell v. SSA

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 12/12/2014 ORDERING 21 that the time for defendant to file a cross-motion for summary judgment is EXTENDED to 1/11/2015. (Reader, L)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
THEOPHOUS H. REAGANS, CSBN 189450
Special Assistant United States Attorney
160 Spear Street, Ste. 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [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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) No. 2:14-CV-01123-CKD
)
) STIPULATION TO EXTEND
Plaintiff,
) BRIEFING SCHEDULE
)
v.
)
)
CAROLYN W. COLVIN,
)
Acting Commissioner of Social
)
Security,
)
)
Defendant.
_______________________________ )
BERNARD GAMBRELL,

The parties stipulate and agree, subject to the Court’s approval, that the time for

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Defendant to file a Cross-Motion for Summary Judgment from DECEMBER 11, 2014 to

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JANUARY 11, 2015. This stipulation is necessary because counsel for Defendant’s

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Counsel has a backlog of cases due in part to his absence from the office both for leave

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and illness. Additionally, Defendant’s counsel is litigating and overseeing several

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bankruptcy adversary proceedings. Defendant’s counsel needs additional time to review

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this case and to prepare a response. This is Defendant’s first request for an extension.

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The parties request this extension in good faith, with no intent to prolong

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proceedings unduly. Defendant apologizes for any inconvenience caused by this delay.

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Dated: DECEMBER 10, 2015

/s/ Jacqueline A. Forslund
(email authorization)
JACQUELINE A. FORSLUND
Attorney for Plaintiff

Dated: DECEMBER 10, 2015

BENJAMIN B. WAGNER
United States Attorney
THEOPHOUS H. REAGANS

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By:

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/s/ Theophous H. Reagans
THEOPHOUS H. REAGANS
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.

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Dated: December 12, 2014

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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