Alcazar v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 10/27/16 ORDERING Defendant response is due by 12/19/2016. (Washington, S)
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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8956
Facsimile: (415) 744-0134
E-Mail: Carolyn.Chen@ssa.gov
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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RIGOBERTO GALVAN ALCAZAR,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
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Defendant.
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Case No.: 2:15-cv-02203-KJN
ORDER APPROVING STIPULATION FOR
AN EXTENSION OF TIME OF 45 DAYS
FOR DEFENDANT’S RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT
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IT IS HEREBY STIPULATED, by and between the parties, through their respective
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counsel of record, that Defendant shall have an extension of time of an additional 45 days to
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respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by
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Defendant. The current due date is November 2, 2016. The new due date will be December 19,
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2016.
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There is good cause for this request. Defendant is seeking this extension due to an
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emergency and workload issues. Defendant’s counsel had a medical emergency on Monday,
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October 24, 2016, and had and will continue to take some leave.
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Defendant is requesting additional time up to and including December 19, 2016, to fully
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review the record and research the issues presented by Plaintiff’s motion for summary judgment.
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This request is made in good faith with no intention to unduly delay the proceedings.
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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.
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Respectfully submitted,
Date: October 26, 2016
CERNEY KREUZE & LOTT, LLP
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s/ Shellie Lott by C.Chen*
(As authorized by e-mail on 10/26/2016)
SHELLIE LOTT
Attorneys for Plaintiff
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Date: October 26, 2016
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PHILLIP A. TALBERT
Acting United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney
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Attorneys for Defendant
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ORDER
APPROVED AND SO ORDERED.
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Dated: October 27, 2016
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