Mendez v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 08/29/17 ORDERING that the date for Plaintiff to file a Motion for Summary Judgment is EXTENDED to 09/21/17. (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 13 Plaintiff, 14 v. 15 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 16 Defendant. 17 ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-00332-AC STIPULATION TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT (FIRST REQUEST) 18 19 Plaintiff Juan Francisco Mendoza Mendez and Defendant Carolyn W. 20 Colvin, Acting Commissioner of Social Security, through their undersigned 21 attorneys, stipulate, subject to this court’s approval, to extend the time by 30 days 22 from August 21, 2017 to September 21, 2017 for Plaintiff to file a Motion for 23 Summary Judgment, with all other dates in the Court’s Order Concerning Review 24 Of Social Security Cases extended accordingly. This is Plaintiff's second and last 25 request for an extension. This request is made at the request of Plaintiff’s counsel 26 to allow additional time to fully research the issues presented. Counsel has had -1- 1 back to back hearings and had to cancel a family vacation just to address three 2 motions that could wait no longer. Counsel currently has 13 overdue motions as of 3 today and is doing all she can do complete and file as many as possible. Counsel’s 4 hearing schedule is significantly lighter for September and counsel will get these 5 and the 11 that are due in the month of September currently. Counsel requests this 6 extension in good faith. 7 DATE: August 25, 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 13 DATE: August 25, 2017 PHILLIP A.TALBET United States Attorney  DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration 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 DATED: August 29, 2017 23 IT IS SO ORDERED: 24 UNITED STATES MAGISTRATE JUDGE 25 26 -2-

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