Tucker v. Commissioner of Social Security

Filing 20

ORDER by Judge Haywood S. Gilliam, Jr. Granting 19 Stipulation Extension of Time. (ndrS, COURT STAFF) (Filed on 5/19/2017)

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1 2 3 4 5 6 Denise Bourgeois Haley Attorney at Law: 143709 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)437-7006 Fax: (562)432-2935 E-Mail: rohlfing.office@rohlfinglaw.com Attorneys for Plaintiff SHAWN TUCKER 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN USDC OF CALIFORNIA RONALD V. DELLUMS 10 11 12 SHAWN TUCKER Plaintiff, 13 v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 15 16 17 Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No.: 3:16-cv-06839-HSG STIPULATION TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT (FIRST REQUEST) 18 19 Plaintiff Shawn Tucker and Defendant Carolyn W. Colvin, Acting 20 Commissioner of Social Security, through their undersigned attorneys, stipulate, 21 subject to this court’s approval, to extend the time by 45 days from May 10, 2017 22 to June 24, 2017 for Plaintiff to file a Motion for Summary Judgment, with all 23 other dates in the Court’s Order Concerning Review Of Social Security Cases 24 extended accordingly. This is Plaintiff's first request for an extension. This request 25 is made at the request of Plaintiff’s counsel to allow additional time to fully 26 research the issues presented. Counsel has multiple overdue motions due to the -1- 1 caseload resulting from the loss of an attorney in June 2016 and the failure of both 2 replacements. Counsel’s caseload is complicated by an extended administrative 3 hearing schedule as well. Counsel is working diligently but can only do one motion 4 or hearing at a time. Counsel’s firm has hired to new associates who are assisting 5 with the briefing; however, it will take time to normalize. Counsel seeks this 6 continuance in good faith and under these rather extraordinary circumstances. 7 DATE: May 17, 2017 Respectfully submitted, LAWRENCE D. ROHLFING 8 /s/ Denise Bourgeois Haley 9 BY: _______________________ Denise Bourgeois Haley Attorney for plaintiff Mr. Shawn Tucker 10 11 12 13 DATE: May 17, 2017 14 15 BRIAN STRETCH Acting United States Attorney /s/ Daniel P. Talbert BY: ____________________________ Daniel P. Talbert Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 16 17 18 19 20 21 22 DATED: May 19, 2017 IT IS SO ORDERED: UNITED STATES DISTRCT JUDGE 23 24 25 26 -2-

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