Torrez v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 10/20/16 ORDERING that Plaintiff's Request for Extension of time is GRANTED. Time is EXTENDED by 14 days from 10/21/16 to 11/4/16 for Plaintiff to file a Motion for Summary Judgment and/or remand. (Mena-Sanchez, L)

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Cyrus Safa

Attorney at Law: 282971
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
JOSETTE JEANEEN TORREZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOSETTE JEANEEN TORREZ

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Plaintiff,
v.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security.
Defendant.

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Case No.: 2:16-cv-01078-KJN
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR SUMMARY
JUDGMENT AND/OR REMAND
(FIRST REQUEST)

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Plaintiff Josette Jeaneen Torrez and Defendant Carolyn W. Colvin, Acting
Commissioner of Social Security, through their undersigned attorneys, stipulate,
subject to this court’s approval, to extend the time by 14 days from October 21,
2016 to November 4, 2016 for Plaintiff to file a motion for summary judgment
and/or remand, with all other dates in the Court’s Order Concerning Review Of
Social Security Cases extended accordingly. Specifically, Defendant’s opposition
shall be due on or before December 5, 2016. Plaintiff’s reply, if any, shall be due
on or before December 26, 2016. This is Plaintiff's first request for an extension.
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This request is made at the request of Plaintiff’s counsel who has been scheduled

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to appear in an out-of-state hearing on short notice (waiving 20 days written

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notice) due to unforeseen circumstances which occurred in another matter.

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Counsel will be traveling and requests additional time to fully research the issues

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presented. Counsel sincerely apologizes to the Court, its staff, and all parties

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involved for any inconvenience this may have caused.

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DATE: October 18, 2016

LAWRENCE D. ROHLFING

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/s/ Cyrus Safa
BY: _______________________
Cyrus Safa

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Attorney for plaintiff Josette Jeaneen Torrez

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Respectfully submitted,

DATE: October 18, 2016
PHILLIP A.TALBET
United States Attorney

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DEBORAH LEE STACHEL
Regional Chief Counsel

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/s/ Jeffrey T. Chen
BY: ____________________________
Jeffrey T. Chen
Special Assistant United States Attorney
Attorneys for defendant Carolyn W. Colvin
|*authorized by e-mail|

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IT IS SO ORDERED.

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Dated: October 20, 2016

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