Hicks v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 5/11/18: The new due date for Plaintiff's Motion for Summary Judgment is June 28, 2018.(Kaminski, H)

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BARBARA MARIE RIZZO (CSBN 172999)
Attorney At Law
P. O. Box 383103
Waikoloa, HI 96738
Telephone: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Plaintiff Stephen D. Hicks

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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________________________________
STEPHEN D. HICKS,
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Plaintiff,
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v.
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NANCY A. BERRYHILL, Acting
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Commissioner of Social Security, )
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Defendant.
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________________________________)

Case No.:

2:17-CV-02480-TLN-KJN

STIPULATION AND ORDER
FOR AN EXTENSION OF TIME FOR
PLAINTIFF TO FILE HIS REPLY
BRIEF

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

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respective counsel, that Plaintiff shall have an extension of time of an
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additional 30 days to file his Motion for Summary Judgement.

This is the

first continuance sought by Plaintiff.
On November 27, 2017, the Court issued a Procedural Order for Social

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Security Review Actions. [Docket No. 3].

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shall file a Motion for Summary Judgment within 45 days after service of the

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Administrative Record.

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11, 2018. [Docket No. 11].

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The Order states that Plaintiff

Defendant filed the Administrative Record on April
Therefore, Plaintiff’s Motion for Summary

Judgment is currently due on May 29, 2018.

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STIPULATION AND [PROPOSED] ORDER

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Plaintiff seeks an extension of

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time of 30 days to file his Motion for Summary Judgment.

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for Plaintiff’s Motion for Summary Judgment will be June 28, 2018.

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There is good cause for this request.
unexpected death in Plaintiff’s family.

The new due date

There has been a sudden and

In addition, another member of

Plaintiff’s family has had an accident resulting in a serious injury.

These

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family emergencies will require Plaintiff’s counsel to travel out of town
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and be out of the office for at least 10 days.

Therefore, Plaintiff is

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respectfully requesting additional time up to and including June 28, 2018 to

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file his Motion for Summary Judgment.

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good faith with no intention to unduly delay the proceedings.
Respectfully submitted,

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Date:

May 10, 2018

“/s/Sharon Lahey”
(As authorized by e-mail on 5/10/2018)
SHARON LAHEY
Attorney for Defendant

Date:

May 10, 2018

“/s/Barbara Marie Rizzo”
BARBARA MARIE RIZZO
Attorney for Plaintiff

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This extension of time is made in

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ORDER
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APPROVED AND SO ORDERED:

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Dated:

May 11, 2018

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STIPULATION AND [PROPOSED] ORDER

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