Wilcox v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER 15 for extension of time signed by Magistrate Judge Dale A. Drozd on 4/27/2015. Defendant have until 5/27/2015 to respond to plaintiff's 14 Motion for Summary Judgment. Parties further stipulation that Court's 6 Scheduling Order shall be MODIFIED accordingly. (Marciel, M)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
JENNIFER A. KENNEY
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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TAMMY J. WILCOX,

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Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

No. 2:14-cv-01636-DAD
STIPULATION AND ORDER FOR A FIRST
EXTENSION OF 30 DAYS FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT AND FILE HER CROSSMOTION FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s Motion for

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Summary Judgment and file her Cross-Motion for Summary Judgment. This extension is

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requested due to Defendant’s counsel’s exceptionally heavy workload at this time, including five

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District Court briefings due and an oral argument scheduled in the next two weeks. Defendant’s

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counsel also has multiple pre-hearing filings due to the Merit Systems Protection Board on April

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24, 2015 and May 8, 2015 regarding an employment law matter in litigation. The additional
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Stip. & Prop. Order to Extend 2:14-CV-01636-DAD

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time requested is needed to adequately research the issues Plaintiff has presented. The current

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due date is April 27, 2015. The new due date will be May 27, 2015.

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

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accordingly.

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Respectfully submitted,
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Dated: April 23, 2015

/s/ *Marc v. Kalagian
(*as authorized by email on Apr. 23, 2015)
MARC V. KALAGIAN
LAW OFFICES OF ROHLFING & KALAGIAN, LLP
Attorney for Plaintiff

Dated: April 23, 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/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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

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Ddad1\orders.soc sec
wilcox1636.stip.eot.ord.docx

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Stip. & Prop. Order to Extend 2:14-CV-01636-DAD

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