Blasquez-Tracy v. Commissioner of Social Security

Filing 12

STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/16/2016 ORDERING the Commissioner of Social Security to file an Answer to the 1 Social Security Complaint by 6/10/2016. (Michel, G.)

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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Acting Regional Chief Counsel, Region IX
Social Security Administration
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys For Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
) Case No. 2:15-CV-2621-CKD
CHERIE BLASQUEZ-TRACY,
)
)
Plaintiff,
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v.
) UNOPPOSED MOTION FOR AN
CAROLYN W. COLVIN, Acting
) EXTENSION OF TIME
Commissioner of Social Security,
) (FIRST REQUEST)
)
Defendant.
)
)
)
)

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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Answer to the Complaint,

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due on May 12, 2016, by 29 days, through and including June10, 2016.

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An extension of time is needed in order to prepare Defendant’s Answer because the

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Commissioner is still in the process of assembling and finalizing the administrative record. This request

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is made in good faith with no intention to unduly delay the proceedings.

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-1Stip. & Prop. Order for Ext
2:15-cv-2621-CKD

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Counsel for Defendant conferred with Plaintiff’s counsel’s by email, who has no opposition to
this motion on May 12, 2016.

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The parties further stipulate the Court’s Scheduling Order shall be modified accordingly.

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Counsel for Defendant apologizes to the Court and opposing counsel for any inconvenience

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caused by this delay.

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Respectfully submitted,

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Date: May 12, 2016
/s/ Jesse S. Kaplan, csb#103726
JESSE S. KAPLAN,
Attorney for Plaintiff

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PHILLIP A. TALBERT
Acting United States Attorney

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By:

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/s/ Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated: May 16, 2016

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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-2Stip. & Prop. Order for Ext
2:15-cv-2621-CKD

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-3Stip. & Prop. Order for Ext
2:15-cv-2621-CKD