Ferris v. Commissioner of Social Security

Filing 25

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 7/27/2015 ORDERING that Defendant shall have until 8/28/2015 to file her cross-motion for summary judgment, with all subsequent deadlines set forth in the Court's scheduling order also extended accordingly. (Zignago, K.)

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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JOHN WILLIAM FERRIS, V,

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Plaintiff,

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v.

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CAROLYN W. COLVIN
Acting Commissioner of Social Security,
Defendant.

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) Case No. 2:14-cv-2569-AC
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) STIPULATION AND ORDER TO
) EXTEND BRIEFING SCHEDULE
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to

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extend Defendant’s time to file her cross-motion for summary judgment with the Court by 30

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days to August 28, 2015, and that all other scheduling dates set forth in the Court’s Case

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Management Order shall be extended accordingly. This is Defendant’s second request for an

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extension of time in this matter, and she requests it in good faith and without any intent to

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prolong proceedings unduly.

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There is good cause for this extension because this case was recently reassigned to new

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counsel for Defendant, who needs additional time to become familiar with the facts of the instant

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case and the issues presented in the opening brief. There is also good cause for this extension

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because counsel for Defendant is currently responsible for numerous district court cases at

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various stages of litigation, as well as conducting discovery and preparing substantive motions in

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proceedings before the Equal Employment Opportunity Commission and Merit Systems

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Protection Board.

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Respectfully submitted,

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Date: July 27, 2015

SACKETT & ASSOCIATES
By:

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Date: July 27, 2015

/s/ Asim H. Modi for Harvey P. Sackett*
HARVEY P. SACKETT
*Authorized by email on July 27, 2015
Attorneys for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER
Based on the foregoing joint stipulation, and for cause shown, THE COURT ORDERS
that Defendant shall have until August 28, 2015 to file her cross-motion for summary judgment,
with all subsequent deadlines set forth in the Court’s scheduling order also extended accordingly.
DATED: July 27, 2015

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______________/S/__________________

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ALLISON CLAIRE
UNITED STATES MAGISTRATE JUDGE

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