Ferris v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 06/01/15 ORDERING that the time for defendant to file her cross-motion for summary judgment is EXTENDED to 06/29/15 with all subsequent deadlines set forth in the Court's scheduling order also extended accordingly. (Benson, A)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
TIMOTHY R. BOLIN, CA SBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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(SACRAMENTO)

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JOHN WILLIAM FERRIS, V,
Plaintiff,
v.

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ACTING COMMISSIONER
OF SOCIAL SECURITY,
Defendant.

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Case No. 2:14-cv-02569-AC
JOINT STIPULATION
TO EXTEND DEFENDANT’S TIME
TO FILE CROSS-MOTION
FOR SUMMARY JUDGMENT

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The parties hereby stipulate, through their undersigned attorneys and subject to the

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Court’s approval, that Defendant shall have an extension of time, up to and including July 29,

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2015, in which to file her cross-motion for summary judgment. Counsel for Defendant has

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longstanding vacation plans that put him out of the country for almost the entire month of June,

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and he is unable to address Plaintiff’s arguments before then.

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This is Defendant’s first request for an extension in this case. She requests it in good faith,
with no intent to prolong proceedings unduly.

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Respectfully submitted,

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Date: May 29, 2015

/s/ Howard D. Olinsky
HOWARD D. OLINSKY
Attorney for Plaintiff

Date: May 29, 2015

BENJAMIN B.WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration

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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney

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ORDER

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Based on the foregoing joint stipulation, and for cause shown, THE COURT ORDERS
that Defendant shall have until July 29, 2015, to file her cross-motion for summary judgment,
with all subsequent deadlines set forth in the Court’s scheduling order also extended accordingly.
Date: June 1, 2015

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