Mericle v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 6/22/15 ORDERING that Defendant shall have a first extension of time of 30 days to respond to Plaintiff's Motion for Summary Judgment and file her Cross-Motion for Summary Judgment. The new due date will be July 25, 2015. The parties further stipulate that the Court's Scheduling Order shall be modifiedaccordingly.(Becknal, R)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
JENNIFER A. KENNEY
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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HOLLY JO MERICLE,

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

Case No.: 2:14-CV-02785-CMK
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,
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 file her Cross-Motion for Summary Judgment. This extension is

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

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employment law hearing next week and travel this week in preparation for the hearing. In

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addition, Defendant’s counsel also has at least 10 district court filings scheduled for the next two

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weeks. The additional time requested is needed to adequately research the issues Plaintiff has
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presented. The current due date is June 25, 2015. The new due date will be July 25, 2015.
Stip. & Prop. Order to Extend 2:14-CV-02785-CMK

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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Dated: June 18, 2015

/s/ *Young Chul Cho
(*as authorized by email on June 16, 2015)
YOUNG CHUL CHO
LAW OFFICES OF LAWRENCE D. ROHLFING
Attorney for Plaintiff

Dated: June 18, 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

ORDER

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APPROVED AND SO ORDERED:
Dated: June 22, 2015

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Stip. & Prop. Order to Extend 2:14-CV-02785-CMK

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