Freeman v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 2/27/2017 ORDERING the Commissioner of Social Security to file a Motion for Summary Judgment by 4/19/2017. (Michel, G.)

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1 2 3 4 5 6 7 8 9 PHILIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration JEFFREY CHEN, CSBN 260516 Special Assistant United States Attorney Social Security Administration 160 Spear Street, Suite 800 San Francisco, CA 94105 Telephone: (415) 977-8939 Facsimile: (415) 744-0134 Email: Jeffrey.Chen@ssa.gov Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 DERICK LLOYD FREEMAN, 15 Plaintiff, 16 v. 17 18 19 NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. 20 ) ) ) ) ) ) ) ) ) ) ) Civil No. 2:16-cv-01988-AC STIPULATION AND PROPOSED ORDER FOR A FIRST EXTENSION OF TIME FOR DEFENDANT TO FILE HER MSJ 21 IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and 22 with the approval of the Court, that Defendant shall have a first extension of time of 30 days to 23 file her MSJ. Defendant respectfully requests this additional time because he has a very heavy 24 workload, and because of an upcoming family vacation to Taiwan that will result in an absence 25 from the office from Monday, February 27 through Friday, March 17, 2017. 26 27 28 Stip. to Extend Def.’s MSJ 1 1 The new due date for Defendant’s MSJ will be Wednesday, April 19, 2017. 2 Respectfully submitted, 3 4 Date: February 27, 2017 5 FORSLUND LAW LLC By: 6 7 8 Date: February 27, 2017 PHILIP A. TALBERT United States Attorney 9 By: 10 11 12 /s/ Jacqueline Forslund* JACQUELINE FORSLUND * By email authorization on Feb. 27, 2017 Attorney for Plaintiff /s/ Jeffrey Chen JEFFREY CHEN Special Assistant United States Attorney Attorneys for Defendant 13 14 15 ORDER 16 17 18 APPROVED AND SO ORDERED: 19 DATED: February 27, 2017 20 21 22 23 24 25 26 27 28 Stip. to Extend Def.’s MSJ 2

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