Wheeler v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 07/10/17 ORDERING that the date for plaintiff to oppose defendant's Motion for Summary Judgment is EXTENDED to 08/21/17. (Benson, A)

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LAW OFFICES OF JOSHUA B. KONS, LLC
Joshua B. Kons (SBN. 244977)
939 West North Avenue, Suite 750
Chicago, IL 60642
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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STEPHANIE WHEELER,
Plaintiff,

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Case No.: 2:16-cv-02827-AC (SS)

vs.
NANCY A. BERRYHILL, ACTING
COMMISSIONER OF SOCIAL SECURITY,

STIPULATION AND PROPOSED ORDER
FOR EXTENSION OF TIME FOR
PLAINTIFF TO FILE OPPOSITION TO
DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT

Defendant.
IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that the time for opposing Defendant’s Motion for Summary Judgment be extended for thirty

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(30) days from July 21, 2017 to August 21, 2017. This is Plaintiff’s first request for an extension.

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

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counsel for Plaintiff – who is a solo practitioner – had an unexpected schedule change in that he

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has to take a highly important deposition of a corporate representative in Delaware relating to a

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complex, nationwide consumer class action case pending in bankruptcy court in Houston, Texas.

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This deposition was recently scheduled for July 21, 2017, and required a significant change to
the Plaintiff counsel’s schedule. Plaintiff’s counsel respectfully requests additional time to

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STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR PLAINTIFF
TO FILE OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
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properly prepare and file Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment.
The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,
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Dated: July 7, 2017

By: /s/ Joshua B. Kons
JOSHUA B. KONS
Attorney for Plaintiff

Dated: July 7, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By: /s/ Tina L. Naicker*
(*as authorized by email on July 7, 2017)

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TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED:

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DATED: July 10, 2017

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STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR PLAINTIFF
TO FILE OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
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