Rasmussen v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 10/1/15 re: 17 EXTENDING the defendant's time to file a cross-motion for summary judgment to 10/30/15. (Meuleman, A)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH L. STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
TIMOTHY R. BOLIN, CA SBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
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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EMILYANN RASMUSSEN,
Plaintiff,
v.

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ACTING COMMISSIONER
OF SOCIAL SECURITY,
Defendant.

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No. 2:15-cv-00079-DAD
JOINT STIPULATION AND ORDER TO
EXTEND DEFENDANT’S TIME TO FILE
CROSS-MOTION FOR
SUMMARY JUDGMENT

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The parties hereby stipulate, through their undersigned attorneys and subject to the

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Court’s approval, that Defendant shall have an extension of time, up to and including

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October 30, 2015, in which to file her cross-motion for summary judgment. Defendant requests

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this extension because of her attorney’s inordinately heavy caseload for the months of September

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and October 2015, including two appellate briefs for the Ninth Circuit Court of Appeals due this

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month and at least nine district court briefs due in October 2015, as well as the additional

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workload of contingency planning in case of a government shutdown.

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Respectfully submitted,

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Date: September 30, 2015

/s/ Joseph Clayton Fraulob
JOSEPH CLAYTON FRAULOB
Attorney for Plaintiff

Date: September 30, 2015

BENJAMIN B.WAGNER
United States Attorney
DEBORAH L. STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney

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ORDER
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Pursuant to the parties’ stipulation, IT IS SO ORDERED.

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Dated: October 1, 2015
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Ddad1\orders.soc sec\rasmussen0079.stip.eot.ord.docx

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