Henricus v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER FOR EXTENSION OF TIME signed by Magistrate Judge Kendall J. Newman on 7/24/15 ORDERING that the time for Defendant to respond to Plaintiff's Motion for Summary Judgment is EXTENDED from 7/23/15, to and including 8/27/15. (Mena-Sanchez, L)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [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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TIMOTHY LEE HENRICUS,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

) Case No.: 2:14-cv-02699-KJN
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) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that the time for Defendant to respond to Plaintiff’s Motion for Summary

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Judgment be extended from July 23, 2015, to and including August 27, 2015. This is

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Defendant’s first request for an extension of time to respond to Plaintiff’s motion. Defense

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counsel needs the additional time to further review the file and prepare a response in this matter

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due to a heavy workload, including several other district court cases, despite due diligence.

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The parties further stipulate that the remaining dates in the Court’s Scheduling Order
shall be modified accordingly.
Defense counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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LAW OFFICE OF ANA L. MOLLEDA

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Dated: July 22, 2015

/s/ Lynn M. Harada for Ana L. Molleda*_
(*as authorized via email on 7/22/15)
ANA L. MOLLEDA
Attorney for Plaintiff

Dated: July 22, 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/ Lynn M. Harada
LYNN M. HARADA
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: July 24, 2015