Rodriguez v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 10/19/15 ORDERING that Defendant shall respond to Plaintiff's Motion for Summary Judgment on or before 10/30/15. It is further ordered that any reply thereto shall be filed on or before 11/19/2015. (Mena-Sanchez, L)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: 415-744-0134
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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DEBORAH ANNA RODRIGUEZ,

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Plaintiff,

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

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) Case No.: 2:15-cv-00231-CKD
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) STIPULATION AND PROPOSED ORDER
) FOR 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 (Docket No. 14) (the “motion”) be extended by fourteen (14) days, from October 16,

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2015 to October 30, 2015. This is Defendant’s second request for an extension of time and the

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third extension of time in the above-captioned matter. Defendant requests this extension because

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the attorney responsible for responding to Plaintiff’s Motion for Summary Judgment recently

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returned to the office from a lengthy unanticipated medical leave and requires additional time to

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adequately address the issues Plaintiff raises in her motion.

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///

STIPULATION & PROPOSED ORDER

CASE NO.: 2:15-cv-00231-CKD

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

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Dated: October 15, 2015

/s/ Jesse S. Kaplan*
JESSE S. KAPLAN
(*As authorized by e-mail on October 15, 2015)

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Attorneys for Plaintiff

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Dated: October 15, 2015

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

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By:

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/s/ Sharon Lahey
SHARON LAHEY
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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IT IS HEREBY ORDERED, pursuant to stipulation, good cause appearing, that
Defendant shall respond to Plaintiff’s Motion for Summary Judgment on or before October 30,
2015. It is further ordered that any reply thereto shall be filed on or before November 19, 2015.

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Dated: October 19, 2015

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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STIPULATION & PROPOSED ORDER

CASE NO.: 2:15-cv-00231-CKD