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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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 (SECOND 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 21 days from October 10, 22 2017 to October 31, 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 is Plaintiff's second request. Counsel intended to 25 do this motion over the weekend; however, the Orange County Fires intervened 26 and counsel is back to work today but is not able to complete this timely. Counsel 27 28 -1- 1 respectfully requests two weeks as she has two opening briefs due today and 2 several joint stipulations waiting in the wings. This request is made at the request 3 of Plaintiff’s counsel to allow additional time to fully research the issues presented. 4 Counsel makes this request in good faith and asks the court’s mercy for delays 5 caused. 6 DATE: October 10, 2017 Respectfully submitted, LAWRENCE D. ROHLFING 7 8 /s/ Denise Bourgeois Haley 9 BY: _______________________ Denise Bourgeois Haley Attorney for plaintiff Dawa Jan Kochai 10 11 12 DATE: October 10, 2017 13 14 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel Social Security Administration 15 /s/ Richard Rodriguez 16 BY: ____________________________ Richard Rodriguez Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 17 18 19 20 IT IS HEREBY ORDERED, that Plaintiff shall have an extension of time, to 21 and include October 24, 2017, in which to file Plaintiff’s Motion for Summary 22 Judgment; and that all other deadlines set forth in the April 3, 2017 Case 23 24 25 Management Order shall be extended accordingly. IT IS SO ORDERED. Dated: October 16, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 26 27 28 -2-

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