Gama v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 3/28/18, ORDERING that plaintiff's time to file a motion for summary judgment brief is EXTENDED to 4/4/2018. (Kastilahn, A)

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JESSE S. KAPLAN CSB#103726
5441 Fair Oaks Bl. Ste. C-1
Carmichael, CA 95608
916/488-3030
916/489-9297 fax

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Attorney for Plaintiff
GAMA o/b/o X.L.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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-o0O0o-

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GAMA on behalf of X.L.,

No.

2:17-CV-01969-CMK

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Plaintiff,
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STIPULATION AND ORDER
FOR EXTENSION OF
TIME TO FILE PLAINTIFF’S
MOTION FOR SUMMARY
JUDGMENT

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v.
NANCY BERRYHILL, Acting
Commissioner of Social Security,
Defendant.
_______________________________________/

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IT IS HEREBY STIPULATED by and between the parties, through their respective

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undersigned attorneys, and with the permission of the Court, that plaintiff’s time to file a motion

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for summary judgment is extended to April 4, 2018.

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This is a first extension. Plaintiff’s counsel did not contact defendant’s counsel requesting
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this extension until March 16, 2018, at which time approximately this date was proposed. The
requested extension is because plaintiff’s counsel twice traveled to Southern California for

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multiple days at the end of February and early March for a conference and for a hearing, and
travels again to Oregon for a hearing before this due date. In between, multiple other hearings

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were done. But primarily the reason for this request was the necessity to spread the due dates of
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several other opening and reply briefs out over approximately a month, many of which otherwise

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fell due in the first part of March. This is the equivalent of an approximately 30-day extension

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from the due date based on when the record was lodged.

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Dated: March 26, 2018
___/s/__________________
JESSE S. KAPLAN
Attorney for Plaintiff

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Counsel, Region IX
Social Security Administration

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Dated: March 26, 2018

/s/ per e-mail authorization

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BEATRICE NA
Special Assistant U.S. Attorney
Attorney for Defendant

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ORDER
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For good cause shown on the basis of this stipulation, the requested extension of
plaintiff’s time to file a motion for summary judgment brief is extended to April 4, 2018.
SO ORDERED.

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Dated: March 28, 2018
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