Aceves v Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 3/12/18 ORDERING that the Plaintiff's Second Amended Motion for Summary Judgment to correct the citations to the record is due on March 15, 2018; Defendant's Opposition to the Second Amended Motion for Summary Judgment is due on April 5, 2018; Plaintiff's Reply in Support of her Second Amended Motion for Summary Judgment is due on April 19, 2018. (Becknal, R)

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LAW OFFICES OF JOSHUA B. KONS, LLC
Joshua B. Kons (SBN. 244977)
939 West North Avenue, Suite 750
Chicago, IL 60642
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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MARY ACEVES,

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Plaintiff,

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vs.
NANCY A. BERRYHILL, ACTING
COMMISSIONER OF SOCIAL
SECURITY,

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STIPULATION AND [PROPOSED]
ORDER FOR REVISED BRIEFING
SCHEDULE

Defendant.

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Case No.: 2:17−CV−01644−EFB

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All parties hereby stipulate and request that the Court enter an order

revising the briefing schedule as set forth below. Good cause exists for the request:
WHEREAS, Plaintiff filed her Complaint on August 8, 2017, and Defendant
filed its Answer on November 30, 2017 and lodged the administrative transcript on

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November 30, 2017.
WHEREAS, Plaintiff filed her Motion for Summary Judgement on January
16, 2018 and an Amended Motion for Summary Judgment on January 18, 2018.
STIPULATION AND [PROPOSED] ORDER FOR REVISED BRIEFING SCHEDULE
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Defendant filed its Opposition to the Plaintiff’s First Amended Motion for
Summary Judgment and its Cross-Motion for Summary Judgement on February 15,
2018.

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WHEREAS, on March 7, 2018, Plaintiff’s counsel realized that several

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citations to the record in its First Amended Summary Judgment Motion were

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incorrect. This was the result of an inadvertent administrative error on the part of

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Plaintiff’s counsel where they cited to the downloaded version of the ERE file
instead of the administrative record provided by the Defendant.

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WHEREAS, Plaintiff’s counsel promptly contacted the Defendant was

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amenable to a new stipulated briefing schedule so that this correction could be

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made.

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NOW THEREFORE, the Parties agree and stipulate to the following new
briefing schedule:
 Plaintiff’s Second Amended Motion for Summary Judgment to correct

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the citations to the record would be due March 15, 2018.
 Defendant’s Opposition to the Second Amended Motion for Summary

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Judgment would be due on April 5, 2018.
 Plaintiff’s Reply in Support of her Second Amended Motion for
Summary Judgement would be due on April 19, 2018.
STIPULATION AND [PROPOSED] ORDER FOR REVISED BRIEFING SCHEDULE
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SO STIPULATED.

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DATED: March 12, 2018.

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LAW OFFICES OF JOSHUA B. KONS,
LLC

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By

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/s/ Joshua B. Kons
Joshua B. Kons
Attorney for Plaintiff
Mary Aceves

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DATED: March 12, 2018.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security
By /s/ Sharon Lahey
Sharon Lahey
Attorney for Defendant
Nancy A. Berryhill

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[PROPOSED] ORDER
Pursuant to stipulation, and for good cause shown, the parties stipulation is
the Court makes the following order:

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The revised briefing schedule in this matter is as follows:
 Plaintiff’s Second Amended Motion for Summary Judgment to correct
the citations to the record would be due March 15, 2018.

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STIPULATION AND [PROPOSED] ORDER FOR REVISED BRIEFING SCHEDULE
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 Defendant’s Opposition to the Second Amended Motion for Summary
Judgment would be due on April 5, 2018.
 Plaintiff’s Reply in Support of her Second Amended Motion for
Summary Judgement would be due on April 19, 2018.

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IT IS SO ORDERED.

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Dated: March 12, 2018.

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STIPULATION AND [PROPOSED] ORDER FOR REVISED BRIEFING SCHEDULE
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