Demelo v. Commissioner of Social Security

Filing 27

STIPULATION and ORDER for an Extension of Time of 2 days for Defendant's Response to Plaintiff's Opening Brief: Defendant shall file its opposition no later than November 12, 2014. signed by Magistrate Judge Barbara A. McAuliffe on 11/12/2014. (Herman, H)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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LUIS DEMELO,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:13-cv-01247-BAM
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 2 DAYS FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S OPENING BRIEF

IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time of an additional two days to

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respond to Plaintiff’s opening brief. This is the second continuance sought by Defendant. The

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new due date will be November 12, 2014.

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Defendant is seeking this extension so that Defendant’s counsel can have additional time

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to fully review the voluminous administrative record and research the issues presented by

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Plaintiff’s opening brief. Despite Defendant’s counsel’s diligent efforts to balance her workload

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and estimate the amount of time needed to fully review the 1000-plus page record and fully

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research the seven issues presented by Plaintiff’s opening brief, she realized she will need

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additional time to adequately respond to Plaintiff’s opening brief.

Stipulation for an Extension of Time; 1:13-cv-01247-BAM

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly. Defendant apologizes for any inconvenience caused by the delay.

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Respectfully submitted,
Date: November 12, 2014

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s/ Michelle Nevarez by C.Chen*
(As authorized by e-mail on 11/11/2014)
MICHELLE NEVAREZ
Attorneys for Plaintiff

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Date: November 12, 2014

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BENJAMIN B. WAGNER
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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The Court adopts the parties’ stipulation. Defendant shall file its opposition no later than
November 12, 2014. The scheduling order shall be modified accordingly.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

November 12, 2014

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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Stipulation for an Extension of Time; 1:13-cv-01247-BAM

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