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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1 2 3 4 5 6 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: Attorneys for Plaintiff JUAN FRANCISCO MENDOZA MENDEZ 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 JUAN FRANCISCO MENDOZA MENDEZ Plaintiff, 13 v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 15 16 Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-00332-AC STIPULATION TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT (FIRST REQUEST) 17 18 Plaintiff Juan Francisco Mendoza Mendez and Defendant Nancy A. Berryhill, Acting 19 Commissioner of Social Security, through their undersigned attorneys, stipulate, subject to this 20 court’s approval, to extend the time by 28 days from July 20, 2017, to August 21, 2017, for 21 22 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 23 additional time to fully research the issues presented. Counsel has had hearings daily since late 24 25 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 26 -1- 1 pending and already continued. With this motion, counsel was out of the office last week on 2 hearings and only briefly in the office on Friday due to family matters and out Monday and 3 Tuesday of this week hearings. Today, Wednesday, counsel was involved in telephonic 4 5 6 7 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 8 /s/ Denise Bourgeois Haley 9 BY: _______________________ Denise Bourgeois Haley Attorney for plaintiff Juan Francisco Mendoza Mendez 10 11 12 DATE: July 26, 2017 PHILLIP A.TALBERT United States Attorney  DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration 13 14 15 16 /s/ Donna W. Anderson 17 BY: ____________________________ Donna W. Anderson Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 18 19 20 21 22 IT IS SO ORDERED. DATED: July 28, 2017. 23 24 25 26 -2-

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