Clark v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 11/19/2015 ORDERING the Commissioner of Social Security to respond to the 18 Motion for Summary Judgment by 12/21/2015; ORDERING the plaintiff to file any reply thereto by 1/11/2016. (Michel, G.)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
California State Bar No. 263027
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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MELISSA HACKWELL CLARK,

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Plaintiff,

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vs.

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CAROLYN W. COLVIN, Acting Commissioner
Of Social Security,

CIVIL NO. 2:15-cv-00375 EFB
STIPULATION AND PROPOSED
ORDER FOR A FIRST EXTENSION
OF 30 DAYS FOR DEFENDANT TO
RESPOND TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT
AND/OR TO FILE ANY CROSSMOTIONS

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Defendant.

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IT IS HEREBY STIPULATED, by and between Melissa Hackwell Clark (Plaintiff) and

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Carolyn W. Colvin, Acting Commissioner of Social Security (Defendant), by and through their

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respective counsel of record, that Defendant shall have an extension of time of thirty (30) days to

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respond to Plaintiff’s motion for summary judgment and/or to file any cross-motions. The current due

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date is November 18, 2015. The new due date will be December 21, 2015. This is the first extension

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of time requested by Defendant and the fourth extension of time requested in the above-captioned

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matter. Defense counsel requires additional time to adequately address the issues Plaintiff raises in her

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motion for summary judgment due to workload as well as ongoing medical leave.
STIPULATION & PROPOSED ORDER

(CIVIL NO. 2:15-cv-00375 EFB)

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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: November 19, 2015

BESS M. BREWER

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By: /s/ Bess M. Brewer*
BESS M. BREWER
(*As authorized by email on November 19, 2015)
Attorneys for Plaintiff

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Dated: November 19, 2015

BENJAMIN B. WAGNER
United States Attorney

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By: /s/ Sharon Lahey
SHARON LAHEY
Special Assistant U. S. Attorney
Attorneys for Defendant

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ORDER

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Pursuant to stipulation, good cause appearing, IT IS SO ORDERED. Defendant shall file her

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response to Plaintiff’s motion for summary judgment on or before December 21, 2015. Plaintiff shall

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file any reply thereto on or before January 11, 2016.

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DATED: November 19, 2015.
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STIPULATION & PROPOSED ORDER

(CIVIL NO. 2:15-cv-00375 EFB)