Campos v. Commissioner of Social Security

Filing 18

Stipulation and Order for a second extension of time to Defendant, signed by Magistrate Judge Barbara A. McAuliffe on 4/22/2015. (Response due by 6/2/2015) (Rosales, O)

1
2
3
4
5
6
7
8
9

BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
KEVIN G. GILL – CSBN 226819
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

10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA

12

FRESNO DIVISION

13
14

AUSENCIO CAMPOS,

15

Plaintiff,

16
17

vs.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,

18
19

Defendant.

)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 1:14-cv-00802-BAM
STIPULATION AND ORDER FOR A
SECOND EXTENSION OF TIME
TO DEFENDANT

20
21

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

22

counsel of record, that Defendant shall have a 45-day extension of time, to and including June 2,

23

2015, to file her responsive brief. This is Defendant’s second request for an extension of time to

24

respond to Plaintiff’s motion. Defendant requests this extension because Defendant’s counsel is

25

currently responding to discovery, conducting and defending depositions, and preparing

26

witnesses and arguments for an upcoming Merit Systems Protection Board hearing. That dispute

27

has grown significantly since Defendant’s first request. As a result, Defendant needs additional

28

time to respond to the issues raised in Plaintiff’s opening brief.

1

1
2

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

3
Respectfully submitted,

4
5

Dated: April 21, 2015

6

LAWRENCE D. ROHLFING
By:

7
8

/s/ Vijay J. Patel*
VIJAY J. PATEL
(* As authorized via email on April 21, 2015)
Attorney for plaintiff Mr. Ausencio Campos

9
10

Dated: April 20, 2015

BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration

11
12
13
By:

15

/s/ Kevin G. Gill
KEVIN G. GILL
Special Assistant U.S. Attorney

16

Attorneys for Defendant

14

17
18

ORDER

19

Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY ORDERED,

20

that Defendant shall have a second extension of time, up to and including June 2, 2015, in which to

21

file a response to Plaintiff’s opening brief. All other deadlines set forth in the June 2, 2014 Case

22

Management Order are modified accordingly.

23

IT IS SO ORDERED.

24
25

Dated:

/s/ Barbara

April 22, 2015

A. McAuliffe

_

UNITED STATES MAGISTRATE JUDGE
26
27
28

2