Felix v. Commissioner of Social Security

Filing 15

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 10/12/2016 ORDERING the Commissioner of Social Security to file a response to the 13 Motion for Summary Judgment by 11/14/2016. (Michel, G.)

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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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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BRIDGETT JANE MARIE FELIX,
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.: 2:16-cv-00698-EFB

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STIPULATION FOR AN EXTENSION OF
TIME OF 30 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 30 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 October 14, 2016. The new due date will be November 14,

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2016.

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There is good cause for this request. Defendant is seeking this extension due to workload

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issues. Since the filing of Plaintiff’s motion for summary judgment, Defendant’s counsel was

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limited in her ability to work on this case due to pre-approved leave and two Equal Employment

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Opportunity Commission (EEOC) cases that had already been extended previously and have

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Stipulation for an Extension of Time; 2:16-cv-00698-EFB

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briefing deadlines around the same time as the original due date of Defendant’s response to the

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Plaintiff’s motion for summary judgment for this case.

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Because of the factors described above, Defendant is requesting additional time up to and

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including November 14, 2016, to fully review the record and research the issues presented by

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Plaintiff’s motion for summary judgment. This request is made in good faith with no intention to

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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 11, 2016

CERNEY KREUZE & LOTT, LLP

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s/ Langley Ellen Kreuze by C.Chen*
(As authorized by e-mail on 10/7/2016)
LANGLEY ELLEN KREUZE
Attorneys for Plaintiff

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Date: October 11, 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 12, 2016

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_________________________________
HON. EDMUND F. BRENNAN
UNITED STATE MAGISTRATE JUDGE

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Stipulation for an Extension of Time; 2:16-cv-00698-EFB

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