Caldwell v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 10/8/15: Plaintiff shall have until December 5, 2015 to file her motion for summary judgment, with all other deadlines extended accordingly. (Kaminski, H)

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Richard A. Whitaker (SBN 58618)
THE LAW OFFICES OF RICHARD A. WHITAKER
2480 Hilborn Road, Suite 102
Fairfield, CA 94534
Ph: [phone]
Attorney for Plaintiff:
Trosalind L. Caldwell

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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Trosalind L. Caldwell,
Plaintiff
v.

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

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Case No.: 2:15-CV-1002-KJN
STIPULATION FOR AN EXTENSION
OF TIME TO FILE PLAINTIFF'S
MOTION FOR SUMMARY JUDGMENT
AND/OR REMAND AND
ORDER THEREON

The parties, though counsel, stipulate to a 60-day extension of time in which plaintiff may file

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her Motion for Summary Judgment and/or Remand of the Commissioner’s Final Decision to

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December 5, 2015. I request the extension due to the fact that at the present time my case load is very

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large, and I have been working 6 to 7 days per week to keep up with the workload. I have hired a new

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associate attorney to assist me but she has been at my office for only 25 days and has yet been able to

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handle some of my cases. I will be 72 years old in 6 weeks and I cannot work at this pace much

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longer. I was advised by my primary care doctor on May 29, 2015 to stop working or risk not be able

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to see my grandchildren grow up. It was then that I advertised for an attorney associate but it took

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time to find a suitable candidate. I need the extra time so I can prepare a quality product for my
client. Defendant's counsel has agreed to a 60-day extension. All remaining deadlines will be
extended accordingly.

Respectfully submitted,

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Dated: October 5, 2015

/s/ Richard A. Whitaker
Richard Allen Whitaker, Esq.
Attorney for Plaintiff

Dated: October 6, 2015

Benjamin B. Wagner
United States Attorney

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/s/ Marcelo Illarmo
Marcelo Illarmo
Special Assistant, U.S. Attorney

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ORDER
Good cause having been shown, the parties’ stipulation (ECF No. 17) is APPROVED.
Plaintiff shall have until December 5, 2015 to file her motion for summary judgment, with all other
deadlines extended accordingly.

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IT IS SO ORDERED.
Dated: October 8, 2015