Mendez v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 07/28/17 ORDERING that the date for Plaintiff to file a Motion for Summary Judgment is EXTENDED to 08/21/17. (Benson, A.)

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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
JUAN FRANCISCO MENDOZA MENDEZ

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JUAN FRANCISCO MENDOZA
MENDEZ
Plaintiff,

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v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 2:17-cv-00332-AC
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR SUMMARY
JUDGMENT
(FIRST REQUEST)

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Plaintiff Juan Francisco Mendoza Mendez and Defendant Nancy A. Berryhill, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate, subject to this

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court’s approval, to extend the time by 28 days from July 20, 2017, to August 21, 2017, for

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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 first
request for an extension. This request is made at the request of Plaintiff’s counsel to allow

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additional time to fully research the issues presented. Counsel has had hearings daily since late

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June 2017. Counsel has tried to complete and handle several motions per week to little avail.
Counsel has canceled her family vacation next week in an effort to catch up on the motions

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pending and already continued. With this motion, counsel was out of the office last week on

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hearings and only briefly in the office on Friday due to family matters and out Monday and

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Tuesday of this week hearings. Today, Wednesday, counsel was involved in telephonic

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conference with the court and now must go to San Diego for a hearing. Counsel respectfully and
in good faith requests an additional 30 days to complete this motion. Counsel has requested this
continuance as soon as she is able and in good faith.

DATE: July 26, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley

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BY: _______________________
Denise Bourgeois Haley
Attorney for plaintiff
Juan Francisco Mendoza Mendez

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DATE: July 26, 2017

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

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/s/ Donna W. Anderson

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BY: ____________________________
Donna W. Anderson
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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IT IS SO ORDERED.
DATED: July 28, 2017.

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