Pickard v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/2/2017 ORDERING that the plaintiff's time to file her Motion and Memorandum in Support of Motion for Summary Judgment herein is EXTENDED for a period of 1 day, to Thursday, 3/2/2017. (Zignago, K.)

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David J. Linden
Attorney at Law
CSBN 41221
Post Office Box 5780
Napa, CA 94581
Tel. [phone]
Fax. [phone]
Email: [e-mail]
Attorney for Plaintiff, Jin Liu

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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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AHSHA PICKARD,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant

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Case No. 2:16-CV-01545-JAM-CMK
STIPULATION AND ORDER EXTENDING
PLAINTIFF'S TIME TO FILE PLAINTIFF’S
MOTION AND MEMORANDUM IN
SUPPORT OF MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED by and between the parties, through their respective
counsel, and subject to the approval of the Court, that the plaintiff’s time to file her Motion and
Memorandum in Support of Motion for Summary Judgment herein is hereby extended for a
period of 1 day, to Thursday, March 2, 2017.
Plaintiff's Motion was due Wednesday, March 1, pursuant to previous stipulation
between the parties through counsel. Plaintiff's Motion was completed Wednesday by 6:30 PM.
Plaintiff's counsel attempted to file the Motion via the Court's ECF system a minimum of ten
times; each time receiving the message that the User Name and/or the Password being used were
Pickard v. Berryhill, Case 2:16-cv-01545-JAM-CMK, Stipulation and Order
Extending Plaintiff’s Time to File Her Motion for Summary Judgment - 1

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incorrect. Plaintiff's counsel informed counsel for defendant via email at 10:40 PM of the

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inability to file the Motion and provided defense counsel with copies of the Motion as an

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attachment to the email communications. Plaintiff's counsel also submitted an After Hours

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Notification to the ECF HelpDesk about his inability to gain access to the ECF system to submit

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the Motion.

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At 9:00 AM on March 2, counsel contacted the ECF Help Desk in Sacramento and

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confirmed that the User Name entered in the system was correct, the individual at the Help Desk

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could not provide information re the Password, but she provided counsel with a new Password

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which was used to successfully submit the aforementioned pleading on March 2.

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For the foregoing reasons, plaintiff requests a one-day extension of time to March 2, 2017

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to submit her Motion and Memorandum in Support of Motion for Summary Judgment herein.

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The Motion and Memorandum has been filed with the Court and is document #17 in the Court's

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Docket.

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Dated: March 2, 2017

/s/ David J. Linden
DAVID J. LINDEN
Attorney at Law
Attorney for Plaintiff

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PHILIP TALBERT
Acting United States Attorney
BOBBIE J. MONTOYA
United States Attorney's Office

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Dated: March 2, 2017

by:

/s/ Michael K. Marriott
MICHAEL K. MARRIOTT
Special Assistant United States Attorney
Attorneys for Defendant
[Authorized via electronic mail 03/02/2017]

Pickard v. Berryhill, Case 2:16-cv-01545-JAM-CMK, Stipulation and Order
Extending Plaintiff’s Time to File Her Motion for Summary Judgment - 2

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PURSUANT TO STIPULATION IT IS SO ORDERED.

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Dated: March 2, 2017

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Pickard v. Berryhill, Case 2:16-cv-01545-JAM-CMK, Stipulation and Order
Extending Plaintiff’s Time to File Her Motion for Summary Judgment - 3