Phachanh v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 2/24/15 ORDERING that Defendant shall file her response to plaintiff's motion for summary judgment on or before 3/26/15. Any reply thereto shall be filed on or before 4/16/15. (Kastilahn, A)

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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 EXTENSION OF TIME
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 second 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 February 25, 2015. The new deadline will be March 27, 2015.
This is the second extension of time requested by Defendant. Defense counsel requests this
extension of time due to an especially heavy caseload in February 2015, including fourteen
district-court briefs as well as two briefs 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

STIPULATION & PROPOSED ORDER

CASE NO. 2:14-CV-01805-AC
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his motion for summary judgment.
The parties have further agreed that, with the Court’s approval, the case management

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order be modified accordingly.

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Date: February 24, 2015

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By: /s/ John V. Johnson
JOHN V. JOHNSON
Attorneys for the Plaintiff
(As authorized by e-mail on February 24, 2015)

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LAW OFFICES OF JOHN V. JOHNSON

Date: February 24, 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

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response to plaintiff’s motion for summary judgment on or before March 26, 2015. Any reply

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thereto shall be filed on or before April 16, 2015.

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DATE: February 24, 2015

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STIPULATION & PROPOSED ORDER

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