Clark v. SSA

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 3/6/15 ORDERING that Plaintiff may have an extension of time, to and including 4/20/2015, in which to file Plaintiff's Opening Brief; Defendant may have an extension of time to 5/20/2015 to file his opposition, if any is forthcoming. any Reply by Plaintiff will be due on 6/10/2015.(Mena-Sanchez, L)

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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 LAURIE ANITA CLARK
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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LAURIE ANITA CLARK,
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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.: 2:14-CV-01586 AC
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE ALLISON CLAIRE, MAGISTRATE JUDGE OF
THE DISTRICT COURT:
Plaintiff Laurie Anita Clark (“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 to April 20,
2015; and that Defendant shall have until May 20, 2015, to file her opposition.
Any reply by plaintiff will be due June 10, 2015.

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A second extension of time is needed because Plaintiff’s Counsel’s Spouse

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undergoes chemotherapy treatment for her Stage IV breast cancer which

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metastasized initially to her liver and continues to progress there and in her lungs,

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throat, and spine which required recent hospitalization to treat. Counsel requires the

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additional time to file the memorandum in support of complaint to allow him to

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devote the appropriate time to assist his Spouse and his two elementary school aged

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children through this obviously stressful experience. Counsel sincerely apologizes

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to the court for any inconvenience this may have had upon it or its staff. This

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request is made at the request of Plaintiff’s counsel to allow additional time to fully

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research the issues presented.

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DATE: March 6, 2015

Respectfully submitted,

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LAW OFFICES OF LAWRENCE D. ROHLFING
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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff LAURIE ANITA CLARK

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DATED: March 6, 2015
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BENJAMIN WAGNER
United States Attorney

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*/S/- Heather M. Moss
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Heather M. Moss
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 April 20, 2015, in which to file Plaintiff’s Opening Brief; Defendant

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may have an extension of time to May 20, 2015 to file his opposition, if any is

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forthcoming. Any reply by plaintiff will be due June 10, 2015.

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IT IS SO ORDERED.
DATE: March 6, 2015

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