Seago v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/8/2017 ORDERING that the time for Plaintiff to file a Motion for Summary Judgment is EXTENDED to 3/31/2017. (Zignago, K.)

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Denise Bourgeois Haley

Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
JEREMIAH BLUE SEAGO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JEREMIAH BLUE SEAGO

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Plaintiff,
v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 2:16-cv-01348-CMK
STIPULATION TO EXTEND TIME
TO FILE OPENING BRIEF
(FIRST REQUEST)

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Plaintiff Jeremiah Blue Seago and Defendant ,Nancy A. Berryhill, Acting
Commissioner of Social Security, through their undersigned attorneys, stipulate,
subject to this court’s approval, to extend the time by 28 days from March 3, 2017
to March 31, 2017 for Plaintiff to file a Motion for Summary Judgment with all
other dates in the Court’s Order Concerning Review Of Social Security Cases
extended accordingly. This is Plaintiff's first request for an extension. This request
is made at the request of Plaintiff’s counsel to allow additional time to fully
research the issues presented. Counsel is in the process of preparing this motion
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when the due date arrived and is not able to complete this motion by 5 pm today

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and has a heavy hearing schedule next week. Counsel is seeking to complete the

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motion and file it prior to the date requested; however, she will have to fit it

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between hearings and has requested 28 days in good faith as an effort to avoid any

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further requests for extension.

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DATE: March 3, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley
BY: _______________________
Denise Bourgeois Haley

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Attorney for plaintiff Mr. Jeremiah Blue Seago

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DATE: March 3, 2017

PHILLIP A.TALBET
United States Attorney

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/s/ Geralyn Gulseth
BY: ____________________________
Geralyn Gulseth for
Hay-Mie Cho
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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Dated: March 8, 2017

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