Brown v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 12/4/15: Plaintiff may file his Motion for Summary Judgment and/or Remand of the Commissioner's Final Decision by January 14, 2016.(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]
Fax: [phone]
Attorney for Plaintiff:
Robert Brown

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UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA

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Robert Brown,
Plaintiff

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

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Case No.: 2:15-CV-01430-CKD
STIPULATION FOR AN EXTENSION
OF TIME TO FILE PLAINTIFF'S
MOTION FOR SUMMARY JUDGMENT
AND/OR REMAND AND PROPOSED
ORDER

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The parties, though counsel, stipulate to a 30-day extension of time in which plaintiff may file

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

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14, 2016. I request the extension due to the fact that at the present time my case load is very large,

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and I have had a number of health issues this past two months, including surgery on October 27,

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2015. I just turned 72 years old on November 29th and do not bounce back as I did when I was

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younger. I need the extra time so I can prepare a quality product for my client. Defendant's counsel

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has agreed to a 30-day extension. All remaining deadlines will be extended accordingly.

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Respectfully submitted,
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Dated: December 2, 2015

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

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Dated: December 2, 2015

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Benjamin B. Wagner
United States Attorney
Deborah Lee Stachel
Acting Regional Chief Counsel, Region IX

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/s/ Chantal Jenkins
Chantal Jenkins
Special Assistant, U.S. Attorney

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IT IS SO ORDERED.

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Dated: December 4, 2015
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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE