Aguilar v. Commissioner of Social Security

Filing 27

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 04/06/18 ORDERING that the date Plaintiff's Reply to the Opposition is due is EXTENDED to 05/11/18. (Benson, A.)

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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
REPLY TO DEFENDANT’S
OPPOSITION TO PLAINTIFF’S
MOTION FOR SUMMARY JUDGMENT
AND PLAINTIFF’S OPPOSITION TO
DEFENDANT’S CROSS-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 Reply to Defendant’s Opposition to Plaintiff’s Motion for Summary Judgment and

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Opposition to Defendant’s Cross-Motion for Summary Judgment in the present case. This is the

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first continuance sought by Plaintiff with regard to this Reply/Opposition. The current due date

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is April 11, 2018. The new due date will be May 11, 2018.

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Good cause exists for this request.

Plaintiff’s counsel has been preparing for and

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attending hearings (Plaintiff’s counsel attended a hearing earlier this week), and has hearings to

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prepare for and attend as soon as next week (the week this Reply/Opposition is due). Further,

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Plaintiff’s counsel has recently been assigned multiple files, and will be assigned more in the

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near future, all of which require detailed review to ensure that any deadlines are met.
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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Therefore, Plaintiff is respectfully requesting additional time up to and including May 11,

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2018, to prepare his Reply to Defendant’s Opposition to Plaintiff’s Motion for Summary

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Judgment and Opposition to Defendant’s Cross-Motion for Summary Judgment. This request is

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made in good faith and with no intention to unduly delay the proceedings.

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Dated: April 5, 2018

MASTAGNI HOLSTEDT, APC

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

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Dated: April 5, 2018

By: _/s/ Ellinor R. Coder________________
(As authorized by email on 04/05/2018)
ELLINOR R. CODER, 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:

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Plaintiff’s Reply to Defendant’s Opposition to Plaintiff’s Motion for Summary Judgment
and Opposition to Defendant’s Cross-Motion for Summary Judgment must be filed by May 11,
2018.

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Dated: April 6, 2018

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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