Johnson v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 11/12/2015 and agreed between the parties to a second extension of time, to 11/12/2015, in which defendant shall file a response to plaintiff's 17 motion for summary judgment. (Yin, K)

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BENJAMIN WAGNER CSBN 163581
United States Attorney
DEBORAH STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
MARLA K. LETELLIER, CSBN 234969
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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SACRAMENTO DIVISION
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KELLY LEE JOHNSON,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN,
Acting Commissioner of
Social Security,

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Defendant.

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CIVIL NO. 2:14-cv-02754-MCE-CMK
STIPULATION AND ORDER FOR
DEFENDANT’S SECOND EXTENSION
OF TIME TO RESPOND TO
PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the undersigned attorneys, subject to the

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approval of the Court, that Defendant shall have a 15 day extension, from October 28, 2015 to

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November 12, 2015, in which to respond to Plaintiff’s Motion for Summary Judgment.

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This is Defendant’s second request for an extension. Defendant’s brief was previously due on

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October 28, 2015. Unfortunately, previous counsel’s unexpected medical leave has necessitated that this

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case be transferred to new counsel as of November 5, 2015. New counsel asks for this short extension

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in order to familiarize herself with the facts of this case and to analyze the legal issues raised by

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Plaintiff. Defendant apologizes for the inconvenience to the Court and to Plaintiff.

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Stip for EOT, 2:14-cv-02754-MCE-CMK

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This request is not meant to cause intentional delay.

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Respectfully submitted,

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BENJAMIN WAGNER
United States Attorney

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Dated: November 5, 2015

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By: /s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant United States Attorney
Attorneys for Defendant
LAW OFFICES OF BESS M. BREWER

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Dated: November 5, 2015

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By: /s/ Bess M. Brewer
BESS M. BREWER
Attorney for Plaintiff
(as approved by email on November 5, 2015)

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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Dated: November 12, 2015

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Stip for EOT, 2:14-cv-02754-MCE-CMK

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