Padlo v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 06/02/16 ORDERING that defendant's date to respond to 16 Motion for Summary Judgment is EXTENDED to 06/30/16. (Benson, A)
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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
JENNIFER A. KENNEY, CSBN 241625
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8945
Facsimile: (415) 744-0134
E-Mail: jennifer.a.kenney@ssa.gov
Attorneys for Defendant
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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CHARLENE ANN PADLO,
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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.
Case No.: 2:15-CV-01953-AC
STIPULATION AND PROPOSED ORDER
FOR A FIRST EXTENSION OF 30 DAYS
FOR DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT AND FILE ITS CROSSMOTION FOR SUMMARY JUDGMENT
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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s Motion for
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Summary Judgment and file her Cross-Motion for Summary Judgment. This extension is
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requested because Defendant’s counsel is experiencing an exceptionally busy workload at this
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time, including three other briefing deadlines before the district court and the Equal Employment
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Opportunity Commission due the same week as the responsive pleading in this case. The
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additional time will enable Defendant’s counsel to adequately research the issues presented in
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this case. The current due date is May 31, 2016. The new due date will be June 30, 2016.
Stip. & Prop. Order to Extend 2:15-CV-01953-AC
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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: May 31, 2016
/s/ Steven Rosales*
(*as authorized by email on May 31, 2016)
STEVEN ROSALES
Attorney for Plaintiff
Dated: May 31, 2016
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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX,
Social Security Administration
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By:
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/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant U.S. Attorney
Attorneys for Defendant
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ORDER
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APPROVED AND SO ORDERED:
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DATED: June 2, 2016
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Stip. & Prop. Order to Extend 2:15-CV-01953-AC
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