Moores v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER FOR EXTENSION OF TIME signed by Magistrate Judge Edmund F. Brennan on 4/13/15 ORDERING that Defendant's response to Plaintiff's Motion for Summary Judgment is due on 5/15/2015.(Mena-Sanchez, L)

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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: [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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SACRAMENTO DIVISION

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KELLY A. MOORES,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:14-cv-02243-EFB

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STIPULATION FOR AN EXTENSION OF
TIME OF 30 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time of an additional 30 days to

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respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by

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Defendant. The current due date is April 15, 2015. The new due date will be May 15, 2015.

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There is good cause for this request. Defendant is seeking this extension due to

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Defendant’s counsel’s heavy workload in the last month and an upcoming hearing occurring

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April 14-15, 2015. In the last month, in addition to her regular district court case workload,

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Defendant’s counsel was re-assigned an Equal Employment Opportunity Commission (EEOC)

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case that could not be assigned to another attorney, which required immediate action in

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preparation for a settlement conference that occurred earlier this week. In addition, Defendant’s

Stipulation for an Extension of Time; 2:14-cv-02243-EFB

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counsel has an upcoming EEOC hearing on April 14-15, 2015, which has involved time-

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intensive preparation, including meeting with multiple witnesses and performing other tasks in

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preparation for the hearing. Because of the factors described above, defense counsel is requesting

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additional time up to fully review the administrative record and research the issues presented by

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Plaintiff’s motion for summary judgment.

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

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Respectfully submitted,
Date: April 9, 2015

LAW OFFICES OF BARBARA ARNOLD

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s/ Barbara Arnold by C.Chen*
(As authorized by e-mail on 4/9/2015)
BARBARA ARNOLD
Attorneys for Plaintiff

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Date: April 9, 2015

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BENJAMIN B. WAGNER
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.

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DATED: April 13, 2015.

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Stipulation for an Extension of Time; 2:14-cv-02243-EFB

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