Phachanh v. Commissioner of Social Security

Filing 15

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 1/26/2015 ORDERING 14 that defendant shall file her response to the motion for summary judgment on or before 2/25/2015, any replies due by 3/17/2015. (Reader, L)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Illinois State Bar No. 6191786
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
California State Bar No. 263027
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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

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CIVIL NO. 2:14-CV-01805-AC
STIPULATION AND PROPOSED
ORDER FOR A FIRST EXTENSION OF
30 DAYS FOR DEFENDANT TO
RESPOND TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between Naen Phachanh (Plaintiff) and
Defendant Commissioner of Social Security Carolyn W. Colvin (Defendant), by and through
their respective counsel of record, that Defendant shall have a first extension of time of thirty
days to respond to Plaintiff’s motion for summary judgment and/or to file any cross-motions
thereto. The current deadline is January 26, 2015. The new deadline will be February 25, 2015.
Defense counsel requests this extension of time due to an especially heavy caseload in January
and February 2015, including twelve district-court dispositive motions as well as two motions
and one oral argument before the Ninth Circuit. As a result, defense counsel requires more time
to adequately address the issues that Plaintiff raises in his joint stipulation. The parties have

STIPULATION & PROPOSED ORDER

CASE NO. 2:14-CV-01805-AC
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further agreed that, with the Court’s approval, the case management order be modified

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accordingly.

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Date: January 26, 2015

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By: /s/ John V. Johnson
JOHN V. JOHNSON
Attorneys for the Plaintiff
(As authorized by e-mail on January 26, 2015)

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LAW OFFICES OF JOHN V. JOHNSON

Date: January 26, 2015

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BENJAMIN B. WAGNER
United States Attorney
By: /s/ Sharon Lahey
SHARON LAHEY
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, IT IS SO ORDERED.
DEFENDANT SHALL FILE HER RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT ON OR BEFORE FEBRUARY 25, 2015. ANY REPLY THERETO SHALL BE
FILED ON OR BEFORE MARCH 17, 2015.
DATE: January 26, 2015

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STIPULATION & PROPOSED ORDER

CASE NO. 2:14-CV-01805-AC
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