Olson v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 2/28/17 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED for thirty five (35) days from 2/27/17 to 4/3/2017. (Mena-Sanchez, L)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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ALLI K. OLSON,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-CV-01987-CKD
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO FILE RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for thirty-

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five (35) days from February 27, 2017, to April 3, 2017 due to current workload demands. This

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is Defendant’s first request for extension. Good cause exists as counsel for Defendant has a 9th

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Circuit brief due at/around the same time as the current deadline and counsel has two other briefs

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due on the same date as the current deadline. Defendant respectfully requests additional time to

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respond to Plaintiff’s Motion for Summary Judgment in order to adequately research and analyze

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the issues presented by Plaintiff. Defendant makes this request in good faith with no intention to

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unduly delay the proceedings.
Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD

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The parties further stipulate that the Court’s Scheduling Order shall be modified

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accordingly.

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Respectfully submitted,

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Dated: February 23, 2017

/s/ *Cyrsu Safa
(*as authorized by email on February 23, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: February 23, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER
APPROVED AND SO ORDERED:

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Dated: February 28, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD

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