Joseph v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 10/17/14 re: 15 EXTENDING Defendant's response to 14 MOTION for SUMMARY JUDGMENT, to 12/2/14. (Meuleman, A)

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1 2 3 4 5 6 7 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: (415) 977-8995 Facsimile: (415) 744-0134 E-Mail: kevin.gill@ssa.gov 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 NEIMA FAIZ JOSEPH, 14 Plaintiff, 15 16 17 vs. CAROLYN COLVIN, Acting Commissioner of Social Security, Defendant. 18 19 ) Case No.: 2:13-cv-02628-CMK ) ) STIPULATION AND PROPOSED ORDER ) FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) 20 IT IS HEREBY STIPULATED, by and between the parties, through their respective 21 counsel of record, that the time for responding to Plaintiff’s Motion for Summary Judgment be 22 extended from October 17, 2014, to December 2, 2014. This is Defendant’s first request for an 23 extension of time to respond to Plaintiff’s motion. Defendant respectfully requests this 24 additional time because the agency is considering reassigning the matter to new counsel. 25 The parties further stipulate that the Court’s Scheduling Order shall be modified 26 accordingly. 27 28 Stip. & Prop. Order for Ext.; 2:13-cv-02628-CMK 1 1 Counsel apologizes to the Court for any inconvenience caused by this delay. 2 3 Respectfully submitted, 4 5 Dated: October 15, 2014 /s/ Jesse S. Kaplan (As authorized via email on October 15, 2014) JESSE S. KAPLAN Attorney for Plaintiff Dated: October 15, 2014 BENJAMIN B. WAGNER United States Attorney DONNA L. CALVERT Regional Chief Counsel, Region IX Social Security Administration 6 7 8 9 10 11 12 By: 14 /s/ Kevin G. Gill KEVIN G. GILL Special Assistant U.S. Attorney 15 Attorneys for Defendant 13 16 17 ORDER 18 19 20 APPROVED AND SO ORDERED: 21 22 Dated: October 17, 2014 23 24 25 26 27 28 Stip. & Prop. Order for Ext.; 2:13-cv-02628-CMK 2

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