Hill v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/1/17 ORDERING that defendant is GRANTED an extension of time of an additional 1 day to respond to Plaintiff's motion for summary judgment; the new due date is 2/22/2017. Defendant's 21 cross-motion for summary judgment is DEEMED timely. (Kastilahn, A)

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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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DAVID PAUL HILL,
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-01651-TLN-CMK
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 1 DAY 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 1 day 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 February 21, 2017. The new due date will be February 22,

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2017.

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Defendant is requesting additional time up to and including February 22, 2017, to fully

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review the record and research the six issues presented by Plaintiff’s 52-page motion for

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summary judgment, as Defendant’s counsel continues to recover from and address her workload

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after her extended leave. This request is made in good faith with no intention to unduly delay the

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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: February 21, 2017

LAW OFFICE B. MARIE RIZZO

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s/ Barbara M. Rizzo by C.Chen*
(As authorized by e-mail on 2/21/2017)
BARBARA M. RIZZO
Attorneys for Plaintiff

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Date: February 21, 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. DEFENDANT’S MOTION (DOC. 21) IS DEEMED
TIMELY.

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Dated: March 1, 2017

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