Freeman v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 5/3/2017 ORDERING that that Defendant shall have a second extension of time of 30 days to file her motion for summary judgment. The new due date for Defendant's motion is Friday, 5/19/2017. (Zignago, K.)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
MICHAEL K. MARRIOTT, CSBN 280890
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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DERICK LLOYD FREEMAN,

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Plaintiff,

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v.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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STIPULATION AND PROPOSED ORDER
FOR A SECOND EXTENSION OF TIME
FOR DEFENDANT TO FILE HER MSJ

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and
with the approval of the Court, that Defendant shall have a second extension of time of 30 days
to file her MSJ. Defendant respectfully requests this additional time because he has a very heavy
workload, including four District Court briefs as well as a Ninth Circuit merits brief that requires
significant time to complete within the next two weeks.

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Civil No. 2:16-cv-01988-AC

Stip. to Extend Def.’s MSJ
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The new due date for Defendant’s MSJ will be Friday, May 19, 2017.

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Respectfully submitted,

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Date: May 2, 2017

FORSLUND LAW LLC

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By:

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Date: May 2, 2017

/s/ Jacqueline Forslund*
JACQUELINE FORSLUND
* By email authorization on May 2, 2017
Attorney for Plaintiff
PHILIP A. TALBERT
United States Attorney

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By:

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/s/ Michael K. Marriott
MICHAEL K. MARRIOTT
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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DATED: May 3, 2017

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Stip. to Extend Def.’s MSJ
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