Vasquez v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 6/16/2017 ORDERING Defendant to respond to 18 Motion for Summary Judgment by 6/30/2017. (Washington, S)

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

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Case No.: 2:16-cv-00941-CMK
STIPULATION AND ORDER 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 third continuance sought by

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Defendant. The current due date is June 16, 2017. The new due date will be June 30, 2017.

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There is good cause for this request. Since the Court’s order of extension dated May 25,

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2017, Defendant’s counsel has been recovering from and diligently addressing a backlog of cases

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and her full workload after her absence from sickness with flu-like symptoms and pre-approved

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leave. Furthermore, Defendant’s counsel continues to have a full workload in the next couple of

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weeks and beyond, specifically including one district court oral argument and an Equal

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Employment Opportunity Commission matter involving discovery that was just assigned to

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Defendant’s counsel this week as an emergency and that could not be assigned to another

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attorney. Therefore, Defendant is respectfully requesting additional time up to and including

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June 30, 2017, to fully review the record and research the issues presented by Plaintiff’s motion

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for summary judgment, as Defendant’s counsel prioritizes this case amongst her new and

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unanticipated pressing immediate deadlines. This request is made in good faith with no intention

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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: June 14, 2017

LAW OFFICES OF LAWRENCE D. ROHLFING

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s/ Steven G. Rosales by C.Chen*
(As authorized by e-mail on 6/14/2017)
STEVEN G. ROSALES
Attorneys for Plaintiff

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Date: June 14, 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: June 16, 2017

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