Uhler v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 1/20/2017 ORDERING the Commissioner of Social Security to respond to the 10 Motion for Summary Judgment by 1/19/2017; ORDERING that the Court's Scheduling Order be modified accordingly. (Michel, G.)

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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,

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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-01255-EFB

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STIPULATION FOR AN EXTENSION OF
TIME OF 2 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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 2 days to

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

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Defendant. The current due date is January 17, 2017. The new due date will be January 19,

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2017.

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There is good cause for this request. As stated in Defendant’s previous request,

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Defendant requested an extension for Defendant’s counsel’s emergency and workload issues,

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including recovering and catching up on her workload from a medical emergency on Monday,

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October 24, 2016. In addition, Defendant’s counsel was rear-ended in a car accident in

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December caused by another driver, and had to take more leave than originally anticipated to

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recover from her injuries and returned to the office on January 9, 2017.

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Because of the factors described above, Defendant is requesting additional time up to and

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including January 19, 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 and addresses her

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

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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: January 17, 2017

CAMPBELL & CLARK

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s/ Robert N. Campbell by C.Chen*
(As authorized by e-mail on 1/17/2017)
ROBERT N. CLARK
Attorneys for Plaintiff

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Date: January 17, 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
APPROVED AND SO ORDERED.

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DATED: January 20, 2017.

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HON. EDMUND F. BRENNAN
UNITED STATE MAGISTRATE JUDGE

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