Thomas A Michalski v. Carolyn Colvin

Filing 14

STIPULATION AND ORDER re 13 Second MOTION for Extension of Time to File Plaintiff's Motion for Summary Judgment with Proposed Order filed by Thomas A. Michalski. Signed by Judge Edward M. Chen on 6/8/16. (bpfS, COURT STAFF) (Filed on 6/8/2016)

Case 3:15-cv-04483-EMC Document 13 Filed 06/07/16 Page 1 of 2

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Dolly M. Trompeter (CSBN 235784)
Attorney At Law
2261 Market Street, No. 185
San Francisco, CA 94114
Telephone:
415 271-8604
Fax:
415 431-0279
Email:
[e-mail]

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Attorney for Plaintiff, Thomas A. Michalski
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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THOMAS A. MICHALSKI,
Plaintiff,

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v.

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CAROLYN W. COLVIN,
Acting Commissioner of
Social Security,

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Defendant.
______________________________

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Case No.: 3:15-cv-4483-EMC

PLAINTIFF’S MOTION FOR EXTENSION OF
TIME IN WHICH TO FILE PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT and PROPOSED
ORDER

Pursuant to N.D.C.A Civil Local Rule 6, Plaintiff, by and through undersigned counsel, respectfully
moves this Court for an enlargement of time of 30 days, up to and including July 9, 2016 in which to file
Plaintiff’s Motion for Summary Judgment. On June 5, 2016, the undersigned counsel emailed with both Mr.

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Rodriguez, SSA Assistant Regional Counsel and also Mr. Win, who is the Supervising SSA Attorney, and

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requested a stipulation agreeing to extend Plaintiff’s time for filing his Motion for Summary Judgment by 30

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days from June 9, 2016 to July 9, 2016; Mr. Rodriguez and Mr. Win said that Defendant would not oppose

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Plaintiff’s motion to extend time.

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This extension is necessary to provide further opportunity for review and analysis of this case, as
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undersigned counsel was not the original attorney on the case and is in the process of exploring the possibility
of Request for Voluntary Remand in order to avoid further litigation in this case. Plaintiff does not believe

3:15 CV 4483 EMC Plaintiff’s Motion to Extend Time to file MSJ with Proposed Order Michalski v.Colvin
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Case 3:15-cv-04483-EMC Document 13 Filed 06/07/16 Page 2 of 2

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that Defendant will be prejudiced by his delay. This is further evidenced by the Defendant’s declining to
oppose this Motion. This is Plaintiff’s second request for an extension.

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I declare under penalty of perjury that the facts recited above and true and correct. Executed this seventh day

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of June 2016 in San Francisco, CA.

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By “/s/_Dolly M. Trompeter”
DOLLY M. TROMPETER, ESQ.
Attorney for Plaintiff

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

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IT IS SO ORDERED that Plaintiff shall have an additional 30 days in which to file his motion for summary

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judgment, up to and including JULY 9, 2016.

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FO

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NO

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D

DERE
________________________________
SO OR
IT IS
HONORABLE EDWARD M. CHEN,
United States District Court Judge
Northern District of California hen
.C
ward M
udge Ed
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Dated: ___________

R NIA

6/8/16
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3:15 CV 4483 EMC Plaintiff’s Motion to Extend Time to file MSJ with Proposed Order Michalski v.Colvin
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