Fortunel v. Commissioner of Social Security

Filing 15

STIPULATION AND ORDER signed by Magistrate Judge Kendall J. Newman on 11/23/2015 ORDERING the plaintiff to file a Motion for Summary Judgment by 12/21/2015. (Michel, G.)

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SHELLIE LOTT, SBN: 246202
Cerney Kreuze & Lott, LLP
42 N. Sutter Street, Suite 400
Stockton, California 95202
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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JOSEFA RENEE FORTUNEL,
Plaintiff,

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v.

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No. 2:15-cv-01198-KJN

CAROLYN W. COLVIN, Acting
Commissioner of Social Security,

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STIPULATION AND [proposed] ORDER
EXTENDING PLAINTIFF’S TIME TO
FILE A MOTION FOR SUMMARY
JUDGMENT

Defendant.

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IT IS HEREBY STIPULATED by and between the parties, through their respective

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undersigned attorneys, with the approval of the Court, that Plaintiff’s time to file A Motion For

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Summary Judgment in the above-referenced case is hereby extended 30 days from the present due

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date of November 19, 2015, to December 21, 2015. This extension is requested because the writer

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has a very heaving briefing schedule prior to the upcoming holiday engagement with family.

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DATED: November 16, 2015

BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX

/s/ Shellie Lott
SHELLIE LOTT,
Attorney for Plaintiff

/s/ Henry L. Chi
HENRY L. CHI,
(As authorized via E-mail on 11/16/15)
Special Assistant U S Attorney
Attorneys for Defendant

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SHELLIE LOTT, SBN: 246202
Cerney Kreuze & Lott, LLP
42 N. Sutter Street, Suite 400
Stockton, California 95202
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA,
SACRAMENTO DIVISION

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JOSEFA RENEE FORTUNEL,

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No. 2:15-cv-01198-KJN

Plaintiff,
v.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,

[proposed] ORDER EXTENDING
PLAINTIFF’S TIME TO FILE A MOTION
FOR SUMMARY JUDGMENT

Defendant.

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Pursuant to the stipulation of the parties showing good cause for a requested first

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extension of Plaintiff’s time to file a Motion For Summary Judgment, the request is hereby

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APPROVED.

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SO ORDERED.

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Dated: November 23, 2015

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