Sullen v. Commissioner of Social Security

Filing 25

ORDER Granting 24 Stipulation for First Extension of Time to File Defendant's Cross-Motion for Summary Judgment. Cross Motions due by 2/6/2012. Signed by Judge Claudia Wilken on 1/11/2012. (ndr, COURT STAFF) (Filed on 1/11/2012)

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MELINDA L. HAAG, SBN CA 132612
United States Attorney
DONNA CALVERT, SBN IL 6191786
Acting Regional Chief Counsel, Region IX
BRENDA M. PULLIN, SBN CO 35181
Special Assistant United States Attorney
Social Security Administration
333 Market Street, Suite 1500
San Francisco, California 94105
Telephone: [phone]
Facsimile: [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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OAKLAND DIVISION

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ESTHER SULLEN,

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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. 4:10-CV-5898-CW
STIPULATION AND PROPOSED ORDER
FOR FIRST EXTENSION OF TIME TO FILE
DEFENDANT’S CROSS-MOTION FOR
SUMMARY JUDGMENT

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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 heavy workload during the past

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month combined with her long-scheduled holiday leave and extended cross-country travel to visit

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family. In addition, reduced staffing makes reassignment of the case to another attorney an

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impossibility, as no other attorney is available to take on additional duties. Several senior attorneys

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have recently left the regional counsel’s office and cannot be replaced due to the hiring freeze.

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Given these constraints, the Commissioner respectfully requests 30 additional days in which to

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complete the Commissioner’s cross-motion for summary judgment. The new due date will be

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February 6, 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: January 10, 2012

/s/ Tony Arjo
(As authorized via e-mail)
TONY ARJO
Attorney for Plaintiff

Dated: January 10, 2012

BENJAMIN B. WAGNER
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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1/19/2012
Dated: ________________

____________________________________
CLAUDIA WILKEN
United States District Judge

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