Jackson v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 5/11/2016 ORDERING that the deadline for Defendant to file her Opposition Brief is EXTENDED 30 days from 5/11/2016 to 6/10/2016. (Zignago, K.)

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BENJAMIN WAGNER CSBN 163581
United States Attorney
DEBORAH STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
MARLA K. LETELLIER, CSBN 234969
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
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
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SACRAMENTO DIVISION
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TERESA L. JACKSON,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN,
Acting Commissioner of
Social Security,

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Defendant.

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CIVIL NO. 2:15-cv-01737-AC
STIPULATION AND PROPOSED
ORDER FOR DEFENDANT’S SECOND
EXTENSION OF TIME TO RESPOND
TO PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the undersigned attorneys, subject to the

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approval of the Court, that the deadline for Defendant to file her Opposition Brief be extended 30 days

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from May 11, 2016 to June 10, 2016. All other deadlines in the Court’s scheduling order are extended

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accordingly.

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This is Defendant’s second request for an extension of time to respond to Plaintiff’s opening

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brief. Counsel makes this request because she was unexpectedly out of the office due to illness during

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the first half of this week. Defendant requests a 30 day extension because of Counsel’s heavy workload

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which includes preparing a Ninth Circuit appellee’s brief as well as dispositive motions in nine Federal

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Stip for EOT, 2:15-cv-01737-AC

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District Court cases between May 10, 2016 and May 31, 2016. Finally, Counsel’s husband will be
having knee surgery in early June and Counsel anticipates being out of the office for three to five days
during this time.
This request is not meant to cause intentional delay.

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Respectfully submitted,

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BENJAMIN WAGNER
United States Attorney

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Dated: May 11, 2016

By: /s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant United States Attorney
Attorneys for Defendant

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JACQUELINE A. FORSLUND, ESQ.

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Dated: May 11, 2016

By: /s/ Jacqueline A. Forslund
JACQUELINE A. FORSLUND
Attorney for Plaintiff
(as approved by email on May 11, 2016)

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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DATED: May 11, 2016

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Stip for EOT, 2:15-cv-01737-AC

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