Oliveras v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT: Good cause appearing, pursuant to stipulation, Defendant shall file her response to plaintiffs motion for summary judgment on or before October 26, 2016. Any reply thereto shall be filed on or before November 10, 2016. Signed by Magistrate Judge Gary S. Austin on 9/27/2016. (Valdez, E)

1
2
3
4
5
6
7
8
9

PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY (CBSN 263027)
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
UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

FRESNO DIVISION

12
13

JEAN R. OLIVERAS,

14

Plaintiff,

15
vs.
16
17

CAROLYN W. COLVIN, Acting
Commissioner Of Social Security,

18

Defendant.

19

)
)
)
)
)
)
)
)
)
)
)

CIVIL NO. 1:16-cv-00015-GSA
STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND
TO MOTION FOR SUMMARY
JUDGMENT

20
21

IT IS HEREBY STIPULATED, by and between Jean R. Oliveras (Plaintiff) and Carolyn W.

22

Colvin, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of

23

record, that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s motion for

24

summary judgment and/or to file any cross-motions thereto. The current deadline is September 26, 2016

25

and the new deadline would be October 26, 2016. The deadline for any reply would be November 10,

26

2016. Defense counsel requests this extension of time due to unanticipated leave from the office and an

27

especially heavy caseload, which includes twelve district-court dispositive motions prior to the

28

requested deadline.
STIPULATION

CASE NO.: 1:16-cv-00015-GSA

1

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

2
Respectfully submitted,
3
4

Dated: September 26, 2016

LAW OFFICES OF LAWRENCE D. ROHLFING
By: /s/ Young Cho*
YOUNG CHO
Attorney for the Plaintiff
(As authorized by email on September 26, 2016).

5
6
7

Attorneys for Plaintiff

8
9
10

Dated: September 26, 2016

11
12
13

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
By: /s/ Sharon Lahey
SHARON LAHEY
Special Assistant U.S. Attorney

14
15

Attorneys for Defendant
16
17
18

ORDER
Good cause appearing, pursuant to stipulation, Defendant shall file her response to plaintiff’s

19
20
21

motion for summary judgment on or before October 26, 2016. Any reply thereto shall be filed on or
before November 10, 2016.

22
23
24
25
26

IT IS SO ORDERED.
Dated:

September 27, 2016

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

27
28
STIPULATION

CASE NO.: 1:16-cv-00015-GSA

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION

CASE NO.: 1:16-cv-00015-GSA

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28