Hale v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/16/17 ORDERING that Plaintiff may have an extension of time, to and including 4/21/17, in which to file Plaintiff's Motion for Summary Judgment or Remand; Defendant may have an extension of time to 5/22/17 to file her opposition, if any is forthcoming. Any reply by Plaintiff will be due 6/12/17. (Mena-Sanchez, L)

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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]

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Attorneys for Plaintiff LISA MARIE HALE

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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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LISA MARIE HALE,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: 2:16-CV-01677 CMK
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE CRAIG M. KELLISON, MAGISTRATE JUDGE
OF THE DISTRICT COURT:
Plaintiff Lisa Marie Hale (“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 April 21, 2017; and that Defendant shall have until May 22, 2017, to file her
opposition. Any reply by plaintiff will be due June 12, 2017.

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

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

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

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

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

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

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

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

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

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file Plaintiff’s Motion for Summary Judgment or Remand.
Counsel for plaintiff does not anticipate this extraordinary request for more
time to become the rule and recognizes it is the extraordinary exception and
sincerely apologizes to the court for any inconvenience this may have had upon it
or its staff.
DATE: March 15, 2017

Respectfully submitted,
LAW OFFICES OF LAWRENCE D. ROHLFING

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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff LISA MARIE HALE

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DATED: March 15, 2017

Phillip A. Talbert
United States Attorney

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*/S/- Ann L. Maley

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_________________________________
Ann L. Maley
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

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and including April 21, 2017, in which to file Plaintiff’s Motion for Summary

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Judgment or Remand; Defendant may have an extension of time to May 22, 2017

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to file her opposition, if any is forthcoming. Any reply by plaintiff will be due

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June 12, 2017.

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IT IS SO ORDERED.

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Dated: March 16, 2017

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