Hernandez v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER 15 for extension of time signed by Magistrate Judge Craig M. Kellison on 8/22/2014. Defendant shall have until 9/22/2014 to file Cross-Motion for Summary Judgment with all subsequent deadlines set forth in Court's 6 Scheduling Order also extended accordingly. (Marciel, M)

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
TIMOTHY R. BOLIN, CA SBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

10
11

UNITED STATES DISTRICT COURT

12

EASTERN DISTRICT OF CALIFORNIA

13

SACRAMENTO DIVISION

14
15
16
17

RUSSELL HERNANDEZ,
Plaintiff,
v.

18
19
20
21

ACTING COMMISSIONER
OF SOCIAL SECURITY,
Defendant.

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

22
23
24
25
26
27
28

-1-

Case No. 2:13-cv-02629
JOINT STIPULATION TO EXTEND
DEFENDANT’S TIME TO FILE
CROSS-MOTION FOR
SUMMARY JUDGMENT

1

The parties hereby stipulate, through their undersigned attorneys and subject to the

2

Court’s approval, that Defendant shall have an extension of time, up to and including

3

September 22, 2014, in which to file her cross-motion for summary judgment. Defendant

4

requests this extension because of her attorney’s inordinately heavy case load for the month of

5

August 2014, including two appellate briefs, seven district court briefs, and an opposition and

6

hearing in district court. The parties request this extension in good faith, with no intent to delay

7

proceedings unduly.

8
9

Respectfully submitted,

10
11

Date: August X, 2014

/s/ Jesse S. Kaplan
JESSE S. KAPLAN
Attorney for Plaintiff

Date: August X, 2014

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

12
13
14
15
16
17

/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney

18
19
20

ORDER
21
Based on the foregoing joint stipulation, and for cause shown, THE COURT ORDERS
22
that Defendant shall have until September 22, 2014, to file her cross-motion for summary
23
judgment, with all subsequent deadlines set forth in the Court’s scheduling order also
24
extended accordingly.
25
Dated: August 22, 2014
26
27
28

-2-