Vongdeng v. Commissioner of Social Security

Filing 25

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 04/08/16 ORDERING that the time for responding to 20 Motion for Summary Judgment is EXTENDED from 4/11/16 to 5/2/16. (Jackson, T)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
ROYA MASSOUMI, CSBN 242697
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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NOUKONE VONGDENG,

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Plaintiff,

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vs.

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

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Case No.: 2:15-CV-01071-CKD
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR DEFENDANT
TO FILE OPPOSITION TO PLAINTIFF’S
MOTION FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from April

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11, 2016, to May 2, 2016. This is Defendant’s second request for extension of time. Defendant

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respectfully requests additional time following a recent unexpected death in counsel for

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Defendant’s family. Defendant makes this request in good faith with no intention to unduly

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delay the proceedings.

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Stip. & Prop. Order to Extend 2:15-CV-01071-CKD

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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:

April 7, 2016

/s/ *Bess Brewer
(*as authorized by email on April 6, 2016)
BESS M. BREWER
Attorney for Plaintiff

Dated:

April 7, 2016

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/ Roya Massoumi
ROYA MASSOUMI
Special Assistant U.S. Attorney
Attorneys for Defendant
Of Counsel:
TINA L. NAICKER
Assistant Regional Counsel
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:
Dated: April 8, 2016

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stip. & Prop. Order to Extend 2:15-CV-01071-CKD

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