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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1 2 3 4 5 Denise Bourgeois Haley Attorney at Law: 143709 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)437-7006 Fax: (562)432-2935 E-Mail: rohlfing.office@rohlfinglaw.com Attorneys for Plaintiff DONITA TARLETON 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 DONITA TARLETON 12 13 Plaintiff, v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 15 Defendant. 16 ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-cv-02516-AC STIPULATION TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT (SECOND REQUEST) 17 18 19 20 21 22 23 24 25 26 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 -1- 1 attorney last July and both replacements not working out. Counsel’s firm has since 2 hired two new attorneys who will relieve the case load but not yet. Hence, 3 counsel’s case load has been fragile for a while and on Saturday, April 15, 2017, 4 counsel was injured in an auto accident, not seriously, but causing her to miss 5 work a few days and be unable to complete certain tasks; this motion being one of 6 the tasks. Counsel will not request further extension and respectfully requests this 7 extension in good faith. 8 DATE: April 24, 2017 Respectfully submitted, LAWRENCE D. ROHLFING 9 /s/ Denise Bourgeois Haley BY: _______________________ Denise Bourgeois Haley 10 11 Attorney for plaintiff Ms. Donita Tarleton 12 13 14 DATE: April 24, 2017 PHILLIP A.TALBERT United States Attorney 15 /s/ Jennifer A. Kenney BY: ____________________________ Jennifer A. Kenney Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 16 17 18 19 20 21 22 IT IS SO ORDERED. DATED: April 25, 2017 23 24 25 26 -2-

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