Lee v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER for an Extension of Time of 45 days for Defendant's Response to Plaintiff's Motion for Summary Judgment: that Defendant shall have a 45-day extension, or until December 15, 2016, in which to file an Opposition to Plaintiffs Opening Brief; and that all other deadlines set forth in the Case Management Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 11/1/2016. (Herman, H)

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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
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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SACRAMENTO DIVISION

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KONG PENG LEE,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:15-cv-01859-BAM
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 45 DAYS FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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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 45 days to

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respond to Plaintiff’s motion for summary judgment. The current due date is October 31, 2016.

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The new due date will be December 15, 2016.

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There is good cause for this request. Defendant is seeking this extension due to an

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emergency and workload issues. Defendant’s counsel had a medical emergency on Monday,

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October 24, 2016, and had and will continue to take some leave.

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Defendant is requesting additional time up to and including December 15, 2016, to fully

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review the record and research the issues presented by Plaintiff’s motion for summary judgment.

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This request is made in good faith with no intention to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,
Date: October 31, 2016

PENA & BROMBERG, ATTORNEYS AT LAW

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s/ Jonathan O. Pena by C.Chen*
(As authorized by e-mail on 10/31/2016)
JONATHAN O. PENA
Attorneys for Plaintiff

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Date: October 31, 2016

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PHILLIP A. TALBERT
Acting 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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Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY

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ORDERED, that Defendant shall have a 45-day extension, or until December 15, 2016, in which

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to file an Opposition to Plaintiff’s Opening Brief; and that all other deadlines set forth in the

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Case Management Order shall be extended accordingly.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

November 1, 2016

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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