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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Denise Bourgeois Haley
Attorney at Law: 143709
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
SHAWN TUCKER

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UNITED STATES DISTRICT COURT

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NORTHERN USDC OF CALIFORNIA RONALD V. DELLUMS

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SHAWN TUCKER
Plaintiff,

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v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 3:16-cv-06839-HSG
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR SUMMARY
JUDGMENT
(FIRST REQUEST)

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Plaintiff Shawn Tucker and Defendant Carolyn W. Colvin, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,

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subject to this court’s approval, to extend the time by 45 days from May 10, 2017

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to June 24, 2017 for Plaintiff to file a Motion for Summary Judgment, with all

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other dates in the Court’s Order Concerning Review Of Social Security Cases

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extended accordingly. This is Plaintiff's first request for an extension. This request

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

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research the issues presented. Counsel has multiple overdue motions due to the
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caseload resulting from the loss of an attorney in June 2016 and the failure of both

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replacements. Counsel’s caseload is complicated by an extended administrative

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hearing schedule as well. Counsel is working diligently but can only do one motion

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or hearing at a time. Counsel’s firm has hired to new associates who are assisting

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with the briefing; however, it will take time to normalize. Counsel seeks this

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continuance in good faith and under these rather extraordinary circumstances.

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DATE: May 17, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Denise Bourgeois Haley

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BY: _______________________
Denise Bourgeois Haley
Attorney for plaintiff Mr. Shawn Tucker

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DATE: May 17, 2017

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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|

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DATED: May 19, 2017
IT IS SO ORDERED:
UNITED STATES DISTRCT JUDGE

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