Taylor v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/1/2017 ORDERING that plaintiff may have an extension of time, to and including 3/15/2017, in which to file Plaintiff's Motion for Summary Judgment or Remand; Defendant may have an extension of time to 4/14/2017 to file her opposition, if any is forthcoming. Any reply by plaintiff will be due 5/4/2017. (Zignago, K.)

1
2
3
4

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]

5
Attorneys for Plaintiff BRITTANY S.M. TAYLOR
6
7
UNITED STATES DISTRICT COURT
8
EASTERN DISTRICT OF CALIFORNIA

9

SACRAMENTO DIVISION

10
11

BRITTANY S.M. TAYLOR,
12
Plaintiff,
13
vs.
14
NANCY A. BERRYHILL, Acting
15
Commissioner of Social Security,
16
Defendant
17

) Case No.: 2:16-CV-00747 CMK
)
) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
)
)
)
)
)
)
)
)

18
19
20
21
22
23
24
25
26

TO THE HONORABLE CRAIG M. KELLISON, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Brittany S.M. Taylor (“Plaintiff”) and defendant Nancy A.
Berryhill, 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 March 15, 2017; and that Defendant shall have until April
14, 2017, to file her opposition. Any reply by plaintiff will be due May 4, 2017.

-1-

1

A final extension of time for plaintiff is needed. As the Court is aware,

2

Plaintiff’s Counsel’s Spouse recently passed away. Due to the press of the holidays

3

and the need to find a caregiver and the required time to acclimate his children to

4

his absence to meet his professional obligations, Counsel requires the additional

5

time to prepare and file Plaintiff’s Motion for Summary Judgment.

6
7

Counsel sincerely apologizes to the court for any inconvenience this may
have had upon it or its staff.

8
9

DATE: February 21, 2017

Respectfully submitted,

10
LAW OFFICES OF LAWRENCE D. ROHLFING
11

/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff

12
13
14
DATED: February 21, 2017
15

BENJAMIN WAGNER
United States Attorney

16
17
18
19
20

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

21
22
23
24
25
26
-2-

1

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

2

and including March 15, 2017, in which to file Plaintiff’s Motion for Summary

3

Judgment or Remand; Defendant may have an extension of time to April 14, 2017

4

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

5

May 4, 2017.

6

IT IS SO ORDERED.

7
8

Dated: March 1, 2017

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
-3-