Vasquez v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER granting 21 Motion for Extension of time signed by Magistrate Judge Craig M. Kellison on 5/25/17. (Kaminski, H)

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PHILLIP A. TALBERT
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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FRANCISCO ROBERTO VASQUEZ,

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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-00941-CMK
MOTION FOR AN EXTENSION OF TIME
OF 21 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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Defendant, through her counsel of record, moves for an extension of time of an additional

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21 days to respond to Plaintiff’s motion for summary judgment. This is the second continuance

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sought by Defendant. The current due date is May 26, 2017. The new due date will be June 16,

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2017.

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There is good cause for this request. Since the filing of Plaintiff’s motion for summary

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judgment, in the last few days, Defendant’s counsel has come down with flu-like symptoms

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which will keep her from filing Defendant’s response to Plaintiff’s Motion for Summary

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Judgment timely. Furthermore, in the next few weeks, Defendant’s counsel has pre-approved

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leave and a continuing full workload of about seven pending District Court briefs and one district

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court hearing to address. Therefore, Defendant is respectfully requesting additional time up to

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and including June 16, 2017, to fully review the record and research the issues presented by

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Plaintiff’s motion for summary judgment, as Defendant’s counsel recovers from her sickness and

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addresses her workload. This request is made in good faith with no intention to unduly delay the

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proceedings.

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Defendant moves that the Court’s Scheduling Order shall be modified accordingly.

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On May 23, 2017, Defendant reached out to Plaintiff through his counsel Steven Rosales

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of Law Offices of Lawrence D. Rohlfing, and Plaintiff through his counsel confirmed on May

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24, 2017 that he had no objection to the motion.

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Respectfully submitted,
Date: May 24, 2017

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PHILLIP A. TALBERT
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

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APPROVED AND SO ORDERED:

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Dated: May 25, 2017

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