Uhler v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER FOR AN EXTENSION OF TIME OF 45 days for Defendant's response to Plaintiff's Motion for Summary Judgment signed by Magistrate Judge Edmund F. Brennan on 12/6/16. The new date will be 1/17/2017. (Mena-Sanchez, L)

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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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THERESA ANN UHLER,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-cv-01255-EFB

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STIPULATION FOR AN EXTENSION OF
TIME OF 45 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 45 days to

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respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by

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Defendant. The current due date is December 2, 2016. The new due date will be January 17,

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2016 2017 (January 16, 2016 2017 is a holiday).

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There is good cause for this request. Defendant is seeking this extension due to an

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emergency and workload issues. About a month ago, Defendant’s counsel had a medical

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emergency on Monday, October 24, 2016, and was on leave for about a week. Since then she

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has been addressing her full workload, including briefing for an Equal Employment Opportunity

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Commission (EEOC) with an extensive record.

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Defendant is requesting additional time up to and including January 17, 2016 2017 to

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fully review the record and research the issues presented by Plaintiff’s motion for summary

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judgment, as Defendant’s counsel addresses her crowded workload since her return and because

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there will be multiple days she will not be able to work in the office due to holiday days. This

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request is made in good faith with no intention 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: December 2, 2016

CAMPBELL & CLARK

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s/ Robert N. Campbell by C.Chen*
(As authorized by e-mail on 12/2/2016)
ROBERT N. CLARK
Attorneys for Plaintiff

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Date: December 2, 2016

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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
APPROVED AND SO ORDERED.

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DATED: December 6, 2016.

_________________________________
HON. EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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