Schmidt v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 11/28/2016 ORDERING that the Defendant shall respond to Plaintiff's Motion for Summary Judgment on or before 12/28/2016. Any reply shall be due on or before 1/17/2017. (Jackson, T)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: 415-744-0134
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
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CHRISTINA SHAWN SCHMIDT,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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) Case No.: 2:16-CV-00516-AC
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) STIPULATION AND PROPOSED ORDER
) FOR EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that the time for Defendant to respond to Plaintiff’s Motion for Summary

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Judgment be extended by 30 days. The current deadline is November 28, 2016, and the new

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deadline would be December 28, 2016. This is Defendant’s first request for an extension of time

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and the second request for an extension of time in the above-captioned matter. Defense counsel

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requests this additional time to adequately address the issues Plaintiff raises in her Motion for

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Summary Judgment due to the undersigned counsel’s current workload, which includes 15

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dispositive district-court briefs due prior to the requested deadline. The parties further stipulate

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that the Court’s Scheduling Order shall be modified accordingly.

STIPULATION & PROPOSED ORDER

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CASE NO. 2:16-CV-00516-AC

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Respectfully submitted,

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Dated: November 22, 2016

/s/ Joseph C. Fraulob*
JOSEPH C. FRAULOB
(*As authorized on November 22, 2016)

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Attorneys for Plaintiff

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Dated: November 22, 2016

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Sharon Lahey
SHARON LAHEY
Special Assistant United States Attorney

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Attorneys for Defendant

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ORDER

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Good cause appearing, and pursuant to stipulation, it is approved and so ORDERED.

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Defendant shall respond to Plaintiff’s Motion for Summary Judgment on or before December 28,

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2016. Any reply shall be due on or before January 17, 2017.

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Dated: November 28, 2016

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STIPULATION & PROPOSED ORDER

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CASE NO. 2:16-CV-00516-AC