Tarleton v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 4/25/2017 ORDERING the plaintiff to file a Motion for Summary Judgment by 5/24/2017. (Michel, G.)

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Denise Bourgeois Haley

Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
DONITA TARLETON

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DONITA TARLETON

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Plaintiff,
v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 2:16-cv-02516-AC
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR SUMMARY
JUDGMENT
(SECOND REQUEST)

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Plaintiff Donita Tarleton and Defendant Nancy A. Berryhill, Acting
Commissioner of Social Security, through their undersigned attorneys, stipulate,
subject to this court’s approval, to extend the time by 30 days from April 24, 2017
to May 24, 2017 for Plaintiff to file a motion for summary judgment, with all other
dates in the Court’s Order Concerning Review Of Social Security Cases extended
accordingly. This is Plaintiff's secondrequest for an extension. This request is made
at the request of Plaintiff’s counsel to allow additional time to fully research the
issues presented. Counsel’s workload has been impacted due to the loss of an
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attorney last July and both replacements not working out. Counsel’s firm has since

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hired two new attorneys who will relieve the case load but not yet. Hence,

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counsel’s case load has been fragile for a while and on Saturday, April 15, 2017,

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counsel was injured in an auto accident, not seriously, but causing her to miss

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work a few days and be unable to complete certain tasks; this motion being one of

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the tasks. Counsel will not request further extension and respectfully requests this

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extension in good faith.

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DATE: April 24, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley
BY: _______________________
Denise Bourgeois Haley

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Attorney for plaintiff Ms. Donita Tarleton

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DATE: April 24, 2017

PHILLIP A.TALBERT
United States Attorney

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/s/ Jennifer A. Kenney
BY: ____________________________
Jennifer A. Kenney
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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IT IS SO ORDERED.
DATED: April 25, 2017

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