Carter v. Colvin

Filing 20

STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE re 19 STIPULATION WITH PROPOSED ORDER Extension of Time filed by Jessica Marie Carter, Carolyn W. Colvin. Signed by Magistrate Judge Kandis A. Westmore on 2/26/15. (sisS, COURT STAFF) (Filed on 2/26/2015)

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Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

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Attorneys for Plaintiff JESSICA MARIE CARTER
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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JESSICA MARIE CARTER,
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Plaintiff,
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vs.
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CAROLYN COLVIN, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: CV 14-03875 KAW
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE KANDIS A. WESTMORE, MAGISTRATE
JUDGE OF THE DISTRICT COURT:
Plaintiff Jessica Marie Carter (“Plaintiff”) and defendant Carolyn Colvin,
Acting Commissioner of Social Security (“Defendant”), through their undersigned
counsel of record, hereby stipulate, subject to the approval of the Court, to extend
the time for Plaintiff to file Plaintiff’s Motion for Summary Judgment or Remand
to March 31, 2015; and that Defendant shall have until April 28, 2015, to file his
opposition, if any is forthcoming. Any reply by plaintiff will be due May 12, 2015.

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A second extension of time is needed because Plaintiff’s Counsel’s Spouse

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undergoes chemotherapy treatment for her Stage IV breast cancer which

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metastasized initially to her liver and continues to progress there and in her lungs,

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throat, and spine which required recent hospitalization to treat. Counsel requires the

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additional time to file the memorandum in support of complaint to allow him to

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devote the appropriate time to assist his Spouse and his two elementary school aged

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children through this obviously stressful experience. Counsel sincerely apologizes

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to the court for any inconvenience this may have had upon it or its staff. This

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request is made at the request of Plaintiff’s counsel to allow additional time to fully

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research the issues presented.

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DATE: February 23, 2015

Respectfully submitted,
LAW OFFICES OF LAWRENCE D. ROHLFING

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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff JESSICA MARIE CARTER

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DATED: February 23, 2015

MELINDA L. HAAG
United States Attorney

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*/S/- Theophous H. Reagans
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Theophous H. Reagans
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

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and including March 31, 2015, in which to file Plaintiff’s Motion for Summary

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Judgment or Remand; Defendant may have an extension of time to April 28,

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2015to file his opposition, if any is forthcoming. Any reply by plaintiff will be due

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May 12, 2015.

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IT IS SO ORDERED.
DATE: 2/26/15
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THE HONORABLE KANDIS A. WESTMORE
UNITED STATES MAGISTRATE JUDGE

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