Odom v. Commissioner of Social Security

Filing 12

Unopposed Motion for Extension Time by Defendant to file her response to settlement letter (Defendant's first request) and order, signed by Magistrate Judge Erica P. Grosjean on 9/12/2016. (Filing Deadline: 9/27/2016) (Rosales, O)

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PHILLIP TALBERT
United States Attorney
DEBORAH LEE STACHEL – CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
RICHARD M. RODRIGUEZ
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
ROBERT ODOM,

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Plaintiff,
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vs.
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CAROLYN W. COLVIIN, Acting Commissioner )
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of the Social Security Administration,
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Defendant.
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Case No: 1:16-CV-00270-EPG
UNOPPOSED MOTION FOR EXTENSION OF
TIME BY DEFENDANT TO FILE HER
RESPONSE TO SETTLEMENT LETTER
(DEFENDANT’S FIRST REQUEST) AND
ORDER

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Pursuant to Fed. R. Civ. P. 6(b), Carolyn W. Colvin, Acting Commissioner of Social

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Security (“Defendant”) hereby moves for a seven-day extension of time from September 20, 2016,

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through and including September 27, 2016.

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Defendant respectfully requests the Court extend the time for Defendant to file Response

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to Plaintiff’s Settlement Letter Request (hereinafter “Defendant’s response”). This is the first

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extension sought by Defendant.

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There is good cause for this request. I have requested settlement authority from my client
and expect a response should be forthcoming by the original response date of September 20, 2016.
Thereafter, I will need time to draft a stipulation and proposed order and discuss the terms of the
stipulation with Plaintiff’s counsel. I anticipate this will take no longer than seven days.

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Stipulation and Order for Extension of Time

1:16-CV-00270-EPG

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

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Counsel for Defendant conferred with Plaintiff’s counsel on September 9, 2016, who has

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no opposition to this motion. The undersigned apologizes to the Court and opposing counsel for

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any inconvenience incurred because of this request.
Respectfully submitted,

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Dated: September 9, 2016

PHILLIP TALBERT
United States Attorney
DEBORAH LEE STACHEL,
Regional Chief Counsel, Region IX
Social Security Administration

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/s/Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant U.S. Attorney

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Attorneys for Defendant

By:

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Dated: September 9, 2016

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/s/Cyrus Safa, Esq.
As authorized by email
CYRUS SAFA, ESQ.
Attorney for Plaintiff

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ORDER

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Pursuant to the parties’ stipulation, Defendant shall file its response to Plaintiff’s confidential
letter statement no later than September 27, 2016. All other dates in the scheduling order issued on
March 2, 2016 (Doc. 5) are modified accordingly.

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IT IS SO ORDERED.
Dated:

September 12, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Order for Extension of Time

1:16-CV-00270-EPG

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