Taylor v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 10/27/2016 ORDERING that plaintiff may have an extension of time to11/28/2016 in which to file Plaintiffs Motion for SummaryJudgment or Remand; Defendant may have an extension of time to 12/28/2016 to file her opposition. Any reply by plaintiff will bedue 01/17/2017. (Butolph, J)

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Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

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Attorneys for Plaintiff BRITTANY S.M. TAYLOR
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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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BRITTANY S.M. TAYLOR,
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Plaintiff,
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vs.
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CAROLYN COLVIN, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: 2:16-CV-00747 CMK
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE CRAIG M. KELLISON, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Brittany S.M. Taylor (“Plaintiff”) and defendant Carolyn Colvin,
Acting Commissioner of Social Security (“Defendant”), through their undersigned
counsel of record, hereby stipulate, subject to the approval of the Court, to extend
the time for Plaintiff to file Plaintiff’s Motion for Summary Judgment or Remand
to November 28, 2016; and that Defendant shall have until December 28, 2016, to
file her opposition. Any reply by plaintiff will be due January 17, 2017.

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An extension of time for plaintiff is needed in order to properly address the

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issues within the administrative record in this matter as well as the demands arising

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from complications related to Counsel Spouse’s terminal illness which has

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unexpectedly worsened in the last few weeks. Due to a deterioration in her

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condition in the last few weeks, Counsel‘s spouse now requires in home medical

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assistance 24 hours a day and Counsel has been required to devout time to

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planning and managing the transition to end of life care. Counsel required time to

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deal with this change in condition and has taken steps to secure the at home

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hospice level care which his spouse now requires in order to better allow him to

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attend to his professional obligations.

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DATE: September 29, 2016

Respectfully submitted,

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LAW OFFICES OF LAWRENCE D. ROHLFING
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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff

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DATED: September 29, 2016 BENJAMIN WAGNER
United States Attorney

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*/S/- Marcelo N. Illarmo
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Marcela N. Illarmo
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

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and including November 28, 2016, in which to file Plaintiff’s Motion for Summary

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Judgment or Remand; Defendant may have an extension of time to December 28,

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2016 to file her opposition, if any is forthcoming. Any reply by plaintiff will be

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due January 17, 2017.

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IT IS SO ORDERED.

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Dated: October 27, 2016

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