Rosales v. Commissioner of Social Security

Filing 27

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 04/26/17 ORDERING that the due date for defendant's Motion for Summary Judgment is EXTENDED to 04/24/17. (Benson, A)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
JACOB M. MIKOW, CSBN 238045
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [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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FAITH MARIE ANAYA ROSALES,

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Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Civil No. 2:16-cv-00761-CMK
STIPULATION AND ORDER FOR A
FOURTH EXTENSION OF TIME FOR
DEFENDANT TO FILE HER MOTION
FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and

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with the approval of the Court, that Defendant shall have a fourth extension of time of 30 days to

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file her Motion for Summary Judgment. Defendant apologizes for missing the filing deadline in

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this case and respectfully requests this additional time. Defendant’s counsel is seeking this

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extension due to a recent change of counsel (from Jeffery Chen to Mr. Chen’s direct supervisor

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Jacob Mikow, the undersigned), management re-assessing heavy workloads, and the expectation

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that a new counsel for Defendant will be assigned to this case in the near future.

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The new due date for Defendant’s Motion for Summary Judgment will be Monday, April
24, 2017.

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Respectfully submitted,

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Date: April 19, 2017

FORSLUND LAW LLC

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By:

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Date: April 19, 2017

/s/ Jacqueline Anna Forslund *
JACQUELINE ANNA FORSLUND
* By email authorization on April 15, 2017
Attorney for Plaintiff
PHILIP A. TALBERT
United States Attorney

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By:

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/s/ Jacob M. Mikow
JACOB M. MIKOW
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated: April 26, 2017

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Stip. to Extend Def.’s MSJ

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