Emmons v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 01/04/16 ORDERING that the date for defendant to reply to the 13 Motion for Summary Judgment is EXTENDED to 02/22/16. (Benson, A)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Acting Regional Chief Counsel, Region IX
Social Security Administration
HENRY L. CHI, CSBN 265009
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO

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SEAN MICHAEL EMMONS,

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Plaintiff,
v.

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CAROLYN W. COLVIN,

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Acting Commissioner of Social Security,

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Defendant.

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CIVIL NO. 2:15-cv-01509-EFB
STIPULATION AND PROPOSED
ORDER FOR A FIRST EXTENSION OF
TIME FOR DEFENDANT TO RESPOND
TO PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that Defendant shall have a first extension of time of 45 days to respond to
Plaintiff’s Motion for Summary Judgment. There is good cause for this extension because of

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Defendant’s Counsel’s workload and the holidays. Despite his diligent efforts, competing
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Emmons
Stip. and Proposed Order for Extension - 2:15-cv-01509-EFB

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deadlines necessitate an extension, including a scheduled oral argument before the Ninth Circuit.
Additionally, Defendant needs additional time to respond to Plaintiff’s arguments. Given these
factors, Defendant respectfully requests an extension and Plaintiff also consents to this extension.
The current due date is January 7, 2016. The new due date will be February 22, 2016.
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: December 30, 2015

/s/ Henry L. Chi for John Vincent Johnson*
(*by email authorization on December 30, 2015)
John Vincent Johnson
Attorney for Plaintiff

Dated: December 30, 2015

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/ Henry L. Chi
Henry L. Chi
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.
DATED: January 4, 2016
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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Stip. and Proposed Order for Extension - 2:15-cv-01509-EFB