Aguilar v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 12/12/2017 EXTENDING Time up to and including 1/22/2018, for Plaintiff to file his Motion for Summary Judgment. (York, M)

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DAVID P. MASTAGNI, ESQ. (SBN 57721)
ANDREW S. DORIOTT, ESQ. (SBN 314740)
MASTAGNI HOLSTEDT
A Professional Corporation
1912 “I” Street
Sacramento, California 95811
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff
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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOAQUIN SILVA AGUILAR,

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Plaintiff,
v.

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COMMISSIONER OF SOCIAL
SECURITY,
Defendant.

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No. 2:17-cv-00089-CKD
Complaint Filed: January 12, 2017
STIPULATION AND PROPOSED
ORDER FOR AN EXTENSION OF
TIME OF 30 DAYS FOR PLAINTIFF’S
MOTION FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Plaintiff shall have an extension of time of an additional thirty (30) days

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to file his Motion for Summary Judgment in the present case. This is the first continuance

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sought by Plaintiff. The current due date is December 22, 2017. The new due date will be

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January 22, 2018 (January 21, 2018, 30 days from December 22, 2017, is a Sunday).

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Good cause exists for this request. Prior counsel assigned to this case, Carolyn M. Orr,

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left the Plaintiff’s firm, Mastagni Holstedt APC, in September, 2017. Present counsel, Andrew

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S. Doriott, took over her caseload at that time, and has been working diligently to manage the

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cases effectively. Plaintiff’s counsel has two social security administration hearings set in the

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next 30 days for which he must prepare. Further, Plaintiff’s counsel has recently been assigned

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additional and unanticipated matters which must be addressed immediately and which cannot be
STIPULATION AND PROPOSED ORDER RE EXTENSION

Joaquin Silva Aguilar v. Commissioner of Social Security

Case No. 2:17-cv-00089-CKD

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assigned to another attorney. Lastly, Plaintiff’s counsel is presently in the process of seeking

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other counsel to either substitute in or otherwise assist with this case.

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Therefore, Plaintiff is respectfully requesting additional time up to and including January

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22, 2018, to prepare his Motion for Summary Judgment. This request is made in good faith and

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with no intention to unduly delay the proceedings.

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Dated: December 6, 2017

MASTAGNI HOLSTEDT, APC

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By: _/s/ Andrew S. Doriott_______________
ANDREW S. DORIOTT, ESQ.
Attorneys for Plaintiff

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Dated: December 6, 2017

By: _/s/ Adam Lazar____________________
(As authorized by email on 12/06/2017)
ADAM LAZAR, ESQ.
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Based on the foregoing stipulation and good cause appearing therefore, IT IS HEREBY
ORDERED that:
Plaintiff’s Motion for Summary Judgment must be filed by January 22, 2018.

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Dated: December 12, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND PROPOSED ORDER RE EXTENSION

Joaquin Silva Aguilar v. Commissioner of Social Security

Case No. 2:17-cv-00089-CKD