Lloyd v. Astrue
Filing
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STIPULATION AND ORDER EXTENDING TIME TO FILE CROSS-MOTION. Signed by Judge Edward M. Chen on 4/30/12. (bpf, COURT STAFF) (Filed on 5/2/2012)
Case3:11-cv-04902-EMC Document19 Filed04/30/12 Page1 of 2
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MELINDA L. HAAG, SBN CA 132612
United States Attorney
DONNA CALVERT, SBN IL 6191786
Acting Regional Chief Counsel, Region IX
Social Security Administration
BRENDA M. PULLIN, SBN CO 35181
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: 415-977-8975
Fax: 415-744-0134
E-mail: Brenda.Pullin@ssa.gov
Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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CHARLIE LLOYD III,
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Plaintiff,
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v.
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MICHAEL J. ASTRUE,
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Commissioner of Social Security
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Defendant.
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____________________________________)
CASE NO. 3:11-cv-4902-EMC
STIPULATION AND PROPOSED ORDER
FOR FIRST EXTENSION OF TIME TO
FILE DEFENDANT’S CROSS-MOTION
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The parties hereby stipulate through counsel, with the Court’s approval as indicated by issuance
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of the attached Order, that Defendant shall have a first extension of time of 30 days to file his
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cross-motion for summary judgment.
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The extension is being sought due to defendant’s counsel’s workload during the past month
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coupled with the Social Security Regional Counsel’s move to new office space at the end of March
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2012—with all the associated preparations, organization, meetings, packing, and unpacking—which
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have taken more of counsel’s time than projected. Defendant’s counsel was responsible for moving her
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own office as well as helping to pack and move common office areas such as the fax and mail center,
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file areas, and unoccupied cubicles. In addition, after the move, unpacking and technological
Case3:11-cv-04902-EMC Document19 Filed04/30/12 Page2 of 2
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setup/troubleshooting of computer equipment has required additional unanticipated time and IT
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assistance before counsel’s office has become fully functional.
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Given these constraints, along with counsel’s existing workload, the Commissioner respectfully
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requests 30 additional days in which to complete the Commissioner’s cross-motion. The new due date
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will be May 30, 2012.
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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Respectfully submitted,
Dated: April 30, 2012
/s/ Robert C. Weems
(As authorized via e-mail)
ROBERT C. WEEMS
Attorney for Plaintiff
Dated: April 30, 2012
MELINDA L. HAAG
United States Attorney
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/s/ Brenda M. Pullin
BRENDA M. PULLIN
Special Assistant U.S. Attorney
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IT IS SO ORDERED:
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R NIA
FO
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. Chen
ward M
udge Ed
NO
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LI
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____________________________________
RED
EDWARD M. CHEN ORDE
SO
IT IS
UNITED STATES DISTRICT JUDGE
A
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4/30/12
Dated: ________________
UNIT
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