Vasquez v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER 18 for extension of time signed by Magistrate Judge Edmund F. Brennan on 1/14/2015. Plaintiff's Opening Brief now due on 1/16/2015. The Court's 5 Scheduling Order is MODIFIED accordingly. (Marciel, M)

1
2
3

KELSEY BROWN, CA #263109
Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383

5

Phone: [phone]
Fax: [phone]
Email: [e-mail]

6

Attorney for Plaintiff

4

7

UNITED STATES DISTRICT COURT

8

EASTERN DISTRICT OF CALIFORNIA

9

SACREMENTO DIVISION

10
11

ONESSIMO VASQUEZ,

12
13
14

Plaintiff,
vs.
COMMISSIONER OF SOCIAL SECURITY

15

18
19
20
21
22
23
24

AMENDED STIPULATED MOTION AND
ORDER FOR EXTENSION OF TIME

Defendant.

16
17

Case # 2:14-CV-01547-EFB

The parties hereby move, with the Court’s approval as indicated by issuance of the
attached Order, that Plaintiff shall have a second extension of time to file Plaintiff’s Opening
Brief.
Counsel for the Plaintiff has fallen ill and is unable to complete the Opening brief at this
time and needs a few extra days to heal and draft the brief. As a result, counsel for Plaintiff
requires additional time to draft the Opening Brief. Plaintiff requests a second extension of time
of 4 days, with a due date of January 16, 2015.
Page 1

MOTION
[2:14-CV-01547-EFB]

Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]

1
2
3
4
5
6

Plaintiff’s counsel attempted to get a stipulation from the attorney of record Tova
Wolking, but his automated email indicates he will be out of the office until January 19, 2015.
Plaintiff’s counsel contacted the attorney covering Mr. Wolking cases, Paul Sachelari. Mr.
Sachelari indicated that although not noticed with the ECF, that Richard Rodriguez is handling
this case. Despite attempts, Plaintiff’s counsel was unable to get ahold of Mr. Rodriguez prior to
the end of the day.

7
8

Plaintiff’s counsel has since been able to get ahold of opposing counsel, who agreed to
this stipulated amended motion.

9
10

The Plaintiff requests that the Court’s Scheduling Order shall be modified accordingly.
Dated January 13, 2015:

/s/ Kelsey M Brown
KELSEY MACKENZIE BROWN CA #263109
Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]
Attorney for Plaintiff

Dated January 13, 2014:

17

s/ KELSEY M. BROWN for Tova Wolking
TOVA WOLKING
(per e-mail authorization of Richard Rodriguez)
Special Assistant U.S. Attorney
Office of the General Counsel

18

Of Attorneys for Defendant

11
12
13
14
15
16

19
20
21
22
23
24

Page 2

MOTION
[2:14-CV-01547-EFB]

Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]

1

ORDER

2
3

The Court adopts the Plaintiff’s motion as outlined above. Plaintiff’s Opening brief is
now due on January 16, 2015. The Court’s Scheduling Order (Doc. 5) is modified accordingly.

4
5

IT IS SO ORDERED.
DATED: January 14, 2015.

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Page 3

MOTION
[2:14-CV-01547-EFB]

Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]