Kochai v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT signed by Magistrate Judge Carolyn K. Delaney on 9/11/17. Time is EXTENDED by 35 days from 9/5/17 to 10/10/2017 for Plaintiff to file a Motion for Summary Judgment.(Mena-Sanchez, L)

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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: rohlfing.office@rohlfinglaw.com Attorneys for Plaintiff DAWA JAN KOCHAI 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 DAWA JAN KOCHAI Plaintiff, 13 v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 15 16 17 Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-00690-CKD STIPULATION TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT (FIRST REQUEST) 18 19 Plaintiff Dawa Jan Kochai and Defendant Carolyn W. Colvin, Acting 20 Commissioner of Social Security, through their undersigned attorneys, stipulate, 21 subject to this court’s approval, to extend the time by 35 days from September 5, 22 2017 to October 10, 2017 for Plaintiff to file a Motion for Summary Judgment, 23 with all other dates in the Court’s Order Concerning Review Of Social Security 24 Cases extended accordingly. This request is made at the request of Plaintiff’s 25 counsel to allow additional time to fully research the issues presented. Counsel 26 currently has 11 motions overdue and is trying to complete all as soon as possible. 27 28 -1- 1 Counsel’s firm lost an attorney last June 2016. Counsel has hired four attorneys’ to 2 handle that attorney’s caseload consecutively and the last one left on Friday. 3 Counsel has been trying to do as many as possible but remains committed to giving 4 each case the time and focus required to present the best argument possible on the 5 client’s behalf. Counsel appreciates that courtesy and patience of the defendant and 6 this court and counsel assures the court that she continues to zealously represent 7 her clients as best possible under the circumstances. Counsel requests this 8 extension in good faith. 9 DATE: September 5, 2017 Respectfully submitted, 10 LAWRENCE D. ROHLFING 11 /s/ Denise Bourgeois Haley 12 BY: _______________________ Denise Bourgeois Haley Attorney for plaintiff Dawa Jan Kochai 13 14 15 DATE: September 5, 2017 16 17 18 19 BY: ____________________________ Richard Rodriguez Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 20 21 22 23 24 25 PHILLIP A.TALBET United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration /s/ Richard Rodriguez IT IS SO ORDERED Dated: September 11, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 26 27 28 -2-

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