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)

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: [phone]
Fax: [phone]
E-Mail: [e-mail]
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-