Grant v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 2/29/16 ORDERING that Defendant shall have until 4/4/2016 to file her cross-motion for summary judgment, with all subsequent deadlines set forth in the Court's scheduling order also extended accordingly. (Kastilahn, A)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH L. STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI, NY SBN 4692018
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
Email: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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JIMMIE R. GRANT. JR.,
Plaintiff,

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

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Defendant.

) Case No. 2:15-cv-1455-CKD
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) STIPULATION AND ORDER TO
) EXTEND BRIEFING SCHEDULE
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to

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extend Defendant’s time to file her cross-motion for summary judgment with the Court by 35

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days to April 4, 2016, and that all other scheduling dates set forth in the Court’s Case

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Management Order shall be extended accordingly. This is Defendant’s first request for an

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extension of time in this matter, and she requests it in good faith and without any intent to

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prolong proceedings unduly.

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There is good cause for this extension because counsel for Defendant is responsible for

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drafting various pleadings before the district courts within the Ninth Circuit, preparing an oral

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argument before the Ninth Circuit, negotiating or litigating attorney fee matters pursuant to the

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Equal Access to Justice Act, and conducting discovery in personnel-related litigation pending

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before the Equal Employment Opportunity Commission.

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Respectfully submitted,

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Date: February 25, 2016

ROHLFING & KALAGIAN, LLP
By:

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Date: February 25, 2016

/s/ Asim H. Modi for Marc V. Kalagian*
MARC V. KALAGIAN
*Authorized by email on February 25, 2016
Attorneys for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
DEBORAH L. STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Based on the foregoing joint stipulation, and for cause shown, THE COURT ORDERS
that Defendant shall have until April 4, 2016 to file her cross-motion for summary judgment,
with all subsequent deadlines set forth in the Court’s scheduling order also extended accordingly.

Dated: February 29, 2016

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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