Beals v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 8/18/16 ORDERING that the deadline for Plaintiff to file his MOTION for Summary Judgment in this action is EXTENDED through 9/1/16. No additional extensions of time will be gran ted to Plaintiff. It is further ORDERED that Defendant's deadline to respond to Plaintiff's MOTION for Summary Judgment is EXTENDED through 10/17/16. All other aspects of the Scheduling Order previously issued in this action remain unchanged. (Mena-Sanchez, L)

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Jared T. Walker (SB#269029)
2020 Capitol Avenue
Suite 7
Sacramento, CA 95811
T: [phone]
F: [phone]
[e-mail]
Attorney for Plaintiff,
TIMOTHY L. BEALS

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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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TIMOTHY L. BEALS,

Case No.: 2:16-cv-00008-CKD

Plaintiff,
v.

JOINT STIPULATION AND PROPOSED
ORDER TO AMEND SCHEDULING
ORDER

CAROLYN W. COLVIN,
Commissioner of Social Security,

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Defendant.
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Plaintiff Timothy L. Beals and defendant Commissioner of Social Security, through their
counsels of record, jointly request to amend the Court’s Scheduling Order in this action as follows.

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IT IS STIPULATED, that the time for Plaintiff to file his Motion for Summary

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Judgment/Remand be extended fourteen (14) days until September 1, 2016. This will be the final

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extension of time Plaintiff may request.

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Plaintiff’s opening brief due to conflicts arising from counsel’s current workload, which is

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complicated based on counsel’s current position as a solo practitioner without another attorney to

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delegate tasks to, as well as the length of the administrative record in this matter which exceeds 1700

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pages. Counsel regrets making this second request and apologizes to the Court and the parties for

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any inconvenience.

Plaintiff’s counsel needs additional time to prepare

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It is further stipulated that Defendant’s deadline to respond to Plaintiff’s Motion for

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Summary Judgment be extended through October 17, 2016. Defendant’s counsel will require this

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requested extension due to pre-existing court deadlines in other matters which conflict with the new

JOINT STIPULATION TO AMEND SCHEDULING ORDER

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briefing schedule Plaintiff requests.

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Dated: August 16, 2016

Respectfully submitted,

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/s/ Jared T. Walker
Jared T. Walker,
Attorney for Plaintiff

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SO STIPULATED:
PHILLIP A. TALBERT
United States Attorney

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Dated: August 16, 2016

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By:

/s/ Ellinor R. Coder*
(*authorized by e-mail on 8/16/2016)
Ellinor R. Coder
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Based on the stipulation of the parties, it is ORDERED, that the deadline for Plaintiff to file

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his motion for summary judgment in this action is extended through September 1, 2016. No

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additional extensions of time will be granted to Plaintiff. It is further ORDERED that Defendant’s

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deadline to respond to Plaintiff’s motion for summary judgment is extended through October 17,

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2016. All other aspects of the Scheduling Order previously issued in this action remain unchanged.

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Dated: August 18, 2016

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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-2JOINT STIPULATION TO AMEND SCHEDULING ORDER