Felix v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 11/16/16 ORDERING that Defendant shall have an extension of time of an additional 14 days to respond to Plaintiff's motion for summary judgment. The new due date will be November 28, 2016.(Becknal, R)

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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 14 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 14 days to

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respond to Plaintiff’s motion for summary judgment. This is the second continuance sought by

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Defendant. The current due date is November 14, 2016. The new due date will be November

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28, 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. Since the Court’s order of extension dated October 12, 2016,

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Defendant’s counsel had a medical emergency on Monday, October 24, 2016, and was on leave

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for about a week.

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Defendant is requesting additional time up to and including November 28, 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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as Defendant’s counsel addresses her workload since her return. This request is made in good

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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: November 10, 2016

CERNEY KREUZE & LOTT, LLP

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s/ Langley Ellen Kreuze by C.Chen*
(As authorized by e-mail on 11/10/2016)
LANGLEY ELLEN KREUZE
Attorneys for Plaintiff

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Date: November 10, 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: November 16, 2016.

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HON. EDMUND F. BRENNAN
UNITED STATE MAGISTRATE JUDGE

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