Grinstead v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 9/5/2014 ORDERING that Defendant shall have an extension of time of an additional 30 days to respond to plaintiff's motion for summary judgment. (Donati, J)

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1 2 3 4 5 6 7 8 BENJAMIN B. WAGNER United States Attorney DONNA L. CALVERT 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: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 HAROLD GRINSTEAD, Plaintiff, 14 15 16 vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, 17 Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:14-cv-00059-KJN STIPULATION FOR AN EXTENSION OF TIME OF 30 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 IT IS HEREBY STIPULATED, by and between the parties, through their respective 20 counsel of record, that Defendant shall have an extension of time of an additional 30 days to 21 respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by 22 Defendant. The current due date is September 5, 2014. The new due date will be October 5, 23 2014. 24 There is good cause for this request. Defendant is seeking this extension due to 25 Defendant’s counsel’s heavy workload in the last two months and continuing heavy workload, 26 and due to pre-approved leave in September. For the last two months, Defendant’s counsel was 27 limited in her ability to work on this case due to two Equal Employment Opportunity 28 Commission (EEOC) cases, one of which had an out-of-state hearing in Phoenix, Arizona, and Stipulation for an Extension of Time; 2:14-cv-00059-KJN 1 1 involved follow-up and written closing briefs after the hearing, while the other had a motion for 2 summary judgment coming due in September. Counsel also had a Ninth Circuit opposition brief 3 due in August, and has another Ninth Circuit answering brief due in the next month, and at least 4 16 pending district court cases at various stages of litigation in the next month. Because of the 5 factors described above, defense counsel is requesting additional time to fully review the 6 administrative record and research the issues presented by Plaintiff’s motion for summary 7 judgment. 8 9 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 10 11 12 Respectfully submitted, Date: September 4, 2014 HADLEY & FRAULOB 13 s/ Joseph Fraulob by C.Chen* (As authorized by e-mail on 9/4/2014) JOSEPH FRAULOB Attorneys for Plaintiff 14 15 16 17 Date: September 4, 2014 18 BENJAMIN B. WAGNER United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 19 20 Attorneys for Defendant 21 22 ORDER 23 24 APPROVED AND SO ORDERED: 25 Dated: September 5, 2014 26 27 28 Stipulation for an Extension of Time; 2:14-cv-00059-KJN 2

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