Perry-Dillard v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 4/16/15 ORDERING that plaintiff may have an extension of time, to and including May 19, 2015, in which to file Plaintiff's Motion for Summary Judgment or Remand; Defendant may have an extension of time to June 18, 2015 to file his opposition, if any is forthcoming. Any reply by plaintiff continues to be due July 8, 2015.(Becknal, R)

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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 SUSAN CAROL PERRY-DILLARD
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SUSAN CAROL PERRY-DILLARD, ) Case No.: 2:14-CV-02025-CMK
)
) STIPULATION TO EXTEND
Plaintiff,
) BRIEFING SCHEDULE
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vs.
)
)
CAROLYN COLVIN, Acting
)
)
Commissioner of Social Security,
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)
Defendant
)

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TO THE HONORABLE CRAIG M. KELLISON, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Susan Carol Perry-Dillard (“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 or Remand to May 19, 2015; and that Defendant shall have until June
18, 2015, to file his opposition. Any reply by plaintiff to be due July 8, 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 Joint Stipulation to allow him to devote the appropriate

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time to assist his Spouse and his two elementary school aged children through this

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obviously stressful experience. Counsel sincerely apologizes to the court for any

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inconvenience this may have had upon it or its staff. This request is made at the

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request of Plaintiff’s counsel to allow additional time to fully research the issues

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presented

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DATE: April 7, 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

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DATED: April 7, 2015
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BENJAMIN WAGNER
United States Attorney

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*/S/- Jennifer Lee Tarn
_________________________________
Jennifer Lee Tarn
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 May 19, 2015, in which to file Plaintiff’s Motion for Summary

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Judgment or Remand; Defendant may have an extension of time to June 18, 2015

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to file his opposition, if any is forthcoming. Any reply by plaintiff continues to be

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due July 8, 2015.

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IT IS SO ORDERED.

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Dated: April 16, 2015

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