Flores v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 5/27/2015 GRANTING request for extension of time. Defendant shall file response to motion for summary judgment by 6/25/2015. (Zignago, K.)

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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JESSE FLORES,
Plaintiff,
vs.

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

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Case No.: 2:14-CV-02650-AC
STIPULATION AND ORDER FOR A FIRST
EXTENSION OF 30 DAYS FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT AND FILE HER CROSSMOTION FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s Motion for

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Summary Judgment and to file her Cross-Motion for Summary Judgment. This first extension is

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requested due to Defendant’s counsel’s exceptionally heavy workload at this time, including

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three District Court briefs due during this shortened week as well as an employment law matter

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that is in active litigation before the Merit Systems Protection Board. The additional time

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requested is needed to adequately research the issues Plaintiff has presented. The new due date

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will be June 25, 2015.

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The parties further stipulate that the remaining deadlines in the Court’s Scheduling Order
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shall be modified accordingly.
Stip. & Prop. Order to Extend 2:14-CV-02650-AC

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Respectfully submitted,

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Dated: May 26, 2015

/s/ *Stephen A. Valizan
(*as authorized by email on May 26, 2015)
STEPHEN A. VALIZAN
LAW OFFICE OF ELIZABETH GADE, INC.
Attorney for Plaintiff

Dated: May 26, 2015

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/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.

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DATED: May 27, 2015

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Stip. & Prop. Order to Extend 2:14-CV-02650-AC

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