Carlson v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 3/10/2017 ORDERING that plaintiff may have an extension of time, to and including 3/29/2017, in which to file Plaintiff's Motion for Summary Judgment or Remand; Defendant may have an extension of time to 4/28/2017 to file his opposition, if any is forthcoming. Any reply by plaintiff will be due 5/19/2017. (Zignago, K.)

1
2
3
4

Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

5
Attorneys for Plaintiff STEVEN R. CARLSON
6
7
UNITED STATES DISTRICT COURT
8
EASTERN DISTRICT OF CALIFORNIA

9

SACRAMENTO DIVISION

10
11
STEVEN R. CARLSON,
12
Plaintiff,
13
vs.
14

NANCY A. BERRYHILL, Acting
15
Commissioner of Social Security,
16
Defendant
17

) Case No.: 2:16-CV-01484 CKD
)
) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
)
)
)
)
)
)
)
)

18
19
20
21
22
23
24
25
26
27
28

TO THE HONORABLE CAROLYN K. DELANEY, MAGISTRATE
JUDGE OF THE DISTRICT COURT:
Plaintiff Steven R. Carlson (“Plaintiff”) and defendant Nancy A. Berryhill,
Acting Commissioner of Social Security (“Defendant”), through their undersigned
counsel of record, hereby stipulate, subject to the approval of the Court, to extend
the time for Plaintiff to file Plaintiff’s Motion for Summary Judgment or Remand
to March 29, 2017; and that Defendant shall have until April 28, 2017, to file his
opposition. Any reply by plaintiff will be due May 19, 2017.

-1-

1

As the Court is aware, after a 5 year battle with terminal stage 4 cancer

2

Plaintiff’s Spouse passed away on September 30, 2016. The aftermath of this

3

traumatic event on both Counsel and his 9 year old son and 7 year old daughter was

4

immeasurable. Compounding the impact of this loss is the fact that Counsel’s

5

spouse was a former employee at Counsel’s Law Firm and her death was far

6

reaching in its impact on Counsel’s professional life as well. Due to the death, the

7

subsequent holiday period, and the need to find a permanent caregiver and the

8

required time to acclimate his children to that presence during his absence to meet

9

his professional obligations, Counsel requires the additional time to prepare and

10

file Plaintiff’s Motion for Summary Judgment or Remand.

11

Counsel for plaintiff does not anticipate this extraordinary request for more

12

time to become the rule and recognizes it is the extraordinary exception and

13

sincerely apologizes to the court for any inconvenience this may have had upon it

14

or its staff.

15

///

16

///

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27
28

-2-

1

DATE: March 8, 2017

2

Respectfully submitted,
LAW OFFICES OF LAWRENCE D. ROHLFING
/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff

3
4
5
6

DATED: March 8, 2017

BENJAMIN WAGNER
United States Attorney

7
8
*/S/- Sundeep Patel

9

_________________________________
Sundeep Patel
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

10
11
12
13
14
15
16
17
18
19
20
21
22
23

IT IS HEREBY ORDERED that plaintiff may have an extension of time, to and
including March 29, 2017, in which to file Plaintiff’s Motion for Summary
Judgment or Remand; Defendant may have an extension of time to April 28, 2017
to file his opposition, if any is forthcoming. Any reply by plaintiff will be due
May 19, 2017.
IT IS SO ORDERED.
Dated: March 10, 2017
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28

-3-