Lloyd v. Astrue

Filing 22

STIPULATION AND ORDER re 21 for Second Extension of Time to File Defendant's Cross-Motion by 6/30/12, filed by Michael J. Astrue. Signed by Judge Edward M. Chen on 6/8/12. (bpf, COURT STAFF) (Filed on 6/8/2012)

Case3:11-cv-04902-EMC Document21 Filed06/02/12 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: [phone]
Fax: [phone]
E-mail: [e-mail]
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 SECOND 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 second 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 compounded workload during the

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past month coupled with the Social Security Regional Counsel’s move to new offices at the end of

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March 2012, which took more of counsel’s time than projected. Defendant’s counsel was responsible

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for moving her own office as well as helping to pack and move common office areas such as the fax and

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mail center, file areas, and unoccupied cubicles. In addition, after the move, unpacking and

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technological setup/troubleshooting of computer equipment required additional unanticipated time and

Case3:11-cv-04902-EMC Document21 Filed06/02/12 Page2 of 2

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IT assistance before counsel’s office could become fully functional.
Defendant’s counsel has been diligently working through the resultant backlog of cases in the
order of their original due dates.

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Given these constraints, along with counsel’s previously existing workload, the Commissioner

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respectfully requests 30 additional days in which to complete the Commissioner’s cross-motion. The

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new due date will be June 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: June 1, 2012

/s/ Robert C. Weems
(As authorized via e-mail)
ROBERT C. WEEMS
Attorney for Plaintiff

Dated: June 1, 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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____________________________________
EDWARD M. CHEN ORDERED
UNITED STATES O
IT IS S DISTRICT JUDGE

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UNIT
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June 8, 2012
Dated: ________________

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