Olson v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/15/2017 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED for two weeks from May 12, 2017 to May 26, 2017. (Becknal, R)

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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 two

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weeks from May 12, 2017 to May 26, 2017. This is Defendant’s third request for extension.

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Good cause exists to grant Defendant’s request for extension. Additional time is required

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because counsel for Defendant had an emergency family matter earlier this week that required

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counsel for Defendant to take unscheduled leave. Defendant respectfully requests additional

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time to respond to Plaintiff’s Motion for Summary Judgment in order to adequately research,

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analyze and respond to the issues presented by Plaintiff. Defendant makes this request in good

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faith with no intention to unduly delay the proceedings. Defendant will diligently meet the new
Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD

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deadline. 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: May 11, 2017

/s/ *Cyrsu Safa
(*as authorized by email on May 11, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: May 11, 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: May 15, 2017

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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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