Valenzuela v. Commissioner of Social Security

Filing 19

STIPULATION AND ORDER signed by Magistrate Judge Kendall J. Newman on 1/22/2015 ORDERING the defendant to respond to the 17 Motion for Summary Judgment/Remand by 2/20/2015. (Michel, G.)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [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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RICARDO VALENZUELA, JR.,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

) Case No.: 2:14-cv-01446-KJN
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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 Defendant to respond to Plaintiff’s Motion for Summary

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Judgment be extended for 30 days until February 20, 2015. This is Defendant’s first request for

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an extension of time to respond to Plaintiff’s motion. Defense counsel needs the additional time

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to further review the file and prepare a response in this matter due to pre-approved leave in

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December and January and a heavy workload, despite due diligence.

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The parties further stipulate that the remaining dates in the Court’s Scheduling Order
shall be modified accordingly.
Defense counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: January 20, 2015

/s/ Lynn M. Harada for Linda S. Ziskin*_______
(*as authorized via email on 1/20/15)
LINDA S. ZISKIN
Attorney for Plaintiff

Dated: January 20, 2015

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

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By:

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/s/ Lynn M. Harada
LYNN M. HARADA
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER:

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APPROVED AND SO ORDERED:

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Dated: January 22, 2015

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