Calkins v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 3/23/2015 EXTENDING time for defendant to serve responses to Plaintiff's Motion for Summary Judgment from 3/20/2015 to 4/20/2015. (Donati, J)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
THEOPHOUS H. REAGANS, CSBN 189450
Special Assistant United States Attorney
160 Spear Street, Ste. 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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) No. 14-cv-01877-AC
)
) STIPULATION TO EXTEND
Plaintiff,
) BRIEFING SCHEDULE
)
v.
)
)
CAROLYN W. COLVIN,
)
Acting Commissioner of Social
)
Security,
)
)
Defendant.
_______________________________ )
KEVIN CALKINS,

The parties stipulate and agree, subject to the Court’s approval, that the time for

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Defendant to serve her response to Plaintiff’s Motion for Summary Judgment is extended

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from March 20, 2015 to April 20, 2014. All other dates in the Court’s Scheduling Order

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are extended accordingly. Defendant needs the extension because of counsel’s heavy

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caseload and press of work. Counsel had seven district court briefs and five district court

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responses and/or answers due this month, in addition to handling numerous Bankruptcy

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Court cases. Because of counsel’s busy schedule, counsel was unable to complete a

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defensibility review and draft a timely response. Defendant apologizes for any

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inconvenience caused by this delay and asks the Court to grant the extension request.

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Defendant requests this extension in good faith, with no intent to prolong

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proceedings unduly. Plaintiff’s counsel has agreed to stipulate to the extension.

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Dated: MARCH 22, 2015

/s/ Jesse Kaplan
(email authorization)
JESSE KAPLAN
Attorney for Plaintiff

Dated: MARCH 22, 2015

BENJAMIN B. WAGNER
United States Attorney
THEOPHOUS H. REAGANS

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By:

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/s/ Theophous H. Reagans
THEOPHOUS H. REAGANS
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.

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DATED: March 23, 2015

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