Steven G. Rosales, Attorney at Law, Law Offices of Lawrence D. Rohlfing, Santa Fe Springs, CA, Attorneys for Plaintiff LYNNE KELLER.
BENJAMIN WAGNER, United States Attorney, Jean M. Turk, Special Assistant United States Attorney, Attorney for Defendant.
STIPULATION TO EXTEND BRIEFING SCHEDULE
CAROLYN K. DELANEY, Magistrate Judge.
TO THE HONORABLE CAROLYN K. DELANEY, MAGISTRATE JUDGE OF THE DISTRICT COURT:
Plaintiff Lynne Keller ("Plaintiff") and defendant Michael Astrue, 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 Opening Brief to August 23, 2013; and that Defendant shall have until September 23, 2013, to file his opposition, if any is forthcoming. Any reply by plaintiff will be due September 30, 2013.
An extension of time for plaintiff is needed due to a serious illness in Counsel's family. Counsel Spouse receives chemotherapy treatment for her Stage IV breast cancer which metastasized initially to her liver and continues to spread to her lungs and spine. Counsel requires the additional time to file the Joint Stipulation to allow him to devote the appropriate time to assist his Spouse and his two kindergarten and pre-school aged children through this obviously stressful experience. 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 August 23, 2013, in which to file Plaintiff's Opening Brief; Defendant may have an extension of time to September 23, 2013 to consider the contentions raised in Plaintiff's Opening Brief, and file any ...