Kochai v. Commissioner of Social Security

Filing 16

ORDER signed by Magistrate Judge Carolyn K. Delaney on 10/16/2017 ORDERING the Plaintiff's due date for Motion for Summary Judgment is EXTENDED to 10/24/2017. (Washington, S)

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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
DAWA JAN KOCHAI

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DAWA JAN KOCHAI
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-00690-CKD
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR SUMMARY
JUDGMENT
(SECOND REQUEST)

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Plaintiff Dawa Jan Kochai and Defendant Carolyn W. Colvin, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,

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subject to this court’s approval, to extend the time by 21 days from October 10,

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2017 to October 31, 2017 for Plaintiff to file a Motion for Summary Judgment,

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with all other dates in the Court’s Order Concerning Review Of Social Security

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Cases extended accordingly. This is Plaintiff's second request. Counsel intended to

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do this motion over the weekend; however, the Orange County Fires intervened

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and counsel is back to work today but is not able to complete this timely. Counsel

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respectfully requests two weeks as she has two opening briefs due today and

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several joint stipulations waiting in the wings. This request is made at the request

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of Plaintiff’s counsel to allow additional time to fully research the issues presented.

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Counsel makes this request in good faith and asks the court’s mercy for delays

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caused.

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DATE: October 10, 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 Dawa Jan Kochai

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DATE: October 10, 2017

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

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/s/ Richard Rodriguez

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

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IT IS HEREBY ORDERED, that Plaintiff shall have an extension of time, to

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and include October 24, 2017, in which to file Plaintiff’s Motion for Summary

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Judgment; and that all other deadlines set forth in the April 3, 2017 Case

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Management Order shall be extended accordingly. IT IS SO ORDERED.
Dated: October 16, 2017
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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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