Bayless v. Commissioner of Social Security

Filing 19

SECOND STIPULATION AND ORDER TO EXTEND TIME. Signed by Judge Joseph C. Spero on 03/29/11. (klhS, COURT STAFF) (Filed on 3/29/2011)

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Bayless v. Commissioner of Social Security Doc. 19 Case3:10-cv-02562-JCS Document18 Filed03/28/11 Page1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Steven G. Rosales Attorney at Law: 222224 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)868-5886 Fax: (562)868-5491 Attorneys for Plaintiff TATANISHA BAYLESS UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA TATANISHA BAYLESS, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security. Defendant. ) Case No. 3:10-CV-02562 JCS ) ) SECOND STIPULATION EXTEND ) TIME ) ) ) ) ) ) ) TO THE HONORABLE JOSEPH SPERO, MAGISTRATE JUDGE OF THE DISTRICT COURT: IT IS HEREBY STIPULATED by and between the parties, through their respective counsel, that Plaintiff shall have a 30 day extension of time, to and including April 27, 2011, in which to motion for summary judgment. While it is not counsel's policy to request a second extension time, counsel reluctantly must do so at this time. Counsel's case load in addition to a procedural error wherein Denise Bourgeois Haley, the attorney to whom this matter was assigned has not completed her admission to this court. Hence, the motion cannot be filed under her name until admission is complete and Denise Bourgeois Haley's case load has not allowed completion of this matter. While Denise Bourgeois Haley seeks to file the Case3:10-cv-02562-JCS Document18 Filed03/28/11 Page2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 motion for summary judgment before the due date, she seeks this second and final extension as the motion will not be done by March 28, 2011. In addition to other deadlines, Denise Bourgeois Haley will be unavailable until Wednesday, March 30, 2011 due to a pressing family matter that is not local. She is leaving today and will not be returning until Wednesday March 30, 2011. This request is made solely at the request of Plaintiff's counsel. Counsel has acted diligently and in good faith in the preparation of this matter; however, counsel has not been able to comply with the current due date of March 28, 2011. Counsel respectfully request that additional time be allowed to Tatanisha Bayless to properly prepare a meaningful motion for summary judgment on her behalf and apologizes to the court for inconveniencing the court in any manner. Bayless respectfully requests that this request be granted. DATE: March 24, 2011 Respectfully submitted, LAW OFFICES OF LAWRENCE D. ROHLFING /s/ Stephen G. Rosales BY: _______________________ Steven G. Rosales Attorney for plaintiff Tatanisha Bayless DATE: March 28, 2011 Melinda Hagg United States Attorney /s/ Kathryn R. Watson BY: ____________________________ Kathryn R. Watson Attorneys for defendant Michael Astrue -2- Case3:10-cv-02562-JCS Document18 Filed03/28/11 Page3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS HEREBY ORDERED that plaintiff may have an extension of time, to and including April 27, 2011, in which Plaintiff's Motion for Summary Judgment; Defendant may have an extension of time to May 20, 2011 to consider the contentions raised in Plaintiff's Motion for Summary Judgment, and file any opposition if necessary. Any reply by plaintiff will be due June 3, 2011. IT IS SO ORDERED. DATE: 03/29/11 UNIT ED S DISTRICT TE C TA RT U O ER N F D IS T IC T O R -3- A C LI FO sep Judge Jo h C. Sp ero R NIA _______________________________________ THE HONORABLE JOSEPH C. SPERO UNITED STATES MAGISTRATE JUDGE NO S RT H

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