Jenkins v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 1/26/17: The time for responding to Plaintiff's Motion for Summary Judgment shall be extended from January 26, 2017, to February 27, 2017. (Kaminski, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ROYA MASSOUMI, CSBN 242697
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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JAVIS JENKINS,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-CV-01137-CMK
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO FILE RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from

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January 26, 2017, to February 27, 2017 due to current workload demands. This is Defendant’s

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first request for extension. Good cause exists as counsel for Defendant has four other pending

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responses due this week. Defendant respectfully requests additional time to respond to

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Plaintiff’s Motion for Summary Judgment in order to adequately research and analyze the issues

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presented by Plaintiff. Defendant makes this request in good faith with no intention to unduly

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delay the proceedings.

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Joint Stipulation and PO for Extension of Time ; 2:16-CV-01137-CMK

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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Dated: January 26, 2017

/s/ *Peter Brixie
(*as authorized by email on January 26, 2017)
PETER BRIXIE
Attorney for Plaintiff

Dated: January 26, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Roya Massoumi
Roya Massoumi
Special Assistant U.S. Attorney
Attorneys for Defendant
Of Counsel:
TINA L. NAICKER
Assistant Regional Counsel
Attorney for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated: January 26, 2017

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Joint Stipulation and PO for Extension of Time ; 2:16-CV-01137-CMK

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