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Savage v. Berryhill, 2:16-CV-01591 AC. (2017)

Court: District Court, E.D. California Number: infdco20170410569 Visitors: 13
Filed: Mar. 27, 2017
Latest Update: Mar. 27, 2017
Summary: STIPULATION TO EXTEND BRIEFING SCHEDULE ALLISON CLAIRE , Magistrate Judge . TO THE HONORABLE ALLISON CLAIRE, MAGISTRATE JUDGE OF THE DISTRICT COURT: Plaintiff Carrie Ruth Savage ("Plaintiff") and defendant Nancy A. Berryhill, 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 to April 12, 2017; and that Defe
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STIPULATION TO EXTEND BRIEFING SCHEDULE

TO THE HONORABLE ALLISON CLAIRE, MAGISTRATE JUDGE OF THE DISTRICT COURT:

Plaintiff Carrie Ruth Savage ("Plaintiff") and defendant Nancy A. Berryhill, 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 to April 12, 2017; and that Defendant shall have untill May 12, 2017, to file her opposition. Any reply by plaintiff will be due June 2, 2017.

As the Court is aware, after a 5 year battle with terminal stage 4 cancer Plaintiff's Spouse passed away on September 30, 2016. The aftermath of this traumatic event on both Counsel and his 9 year old son and 7 year old daughter was immeasurable. Compounding the impact of this loss is the fact that Counsel's spouse was a former employee at Counsel's Law Firm and her death was far reaching in its impact on Counsel's professional life as well. Due to the death, the subsequent holiday period, and the need to find a permanent caregiver and the required time to acclimate his children to that presence during his absence to meet his professional obligations, Counsel requires the additional time to prepare and file Plaintiff's Motion for Summary Judgment.

Counsel for plaintiff does not anticipate this extraordinary request for more time to become the rule and recognizes it is the extraordinary exception and sincerely apologizes to the court for any inconvenience this may have had upon it or its staff.

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

IT IS HEREBY ORDERED that plaintiff may have an extension of time, to and including April 12, 2017, in which to file Plaintiff's Motion for Summary Judgment; Defendant may have an extension of time to May 12, 2017 to file her opposition, if any is forthcoming. Any reply by plaintiff will be due June 2, 2017.

IT IS SO ORDERED.

Source:  Leagle

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