Moores v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER FOR EXTENSION OF TIME signed by Magistrate Judge Edmund F. Brennan on 5/18/15 ORDERING that Defendant's response to Plaintiff's Motion for Summary Judgment is DUE on 5/22/2015. (Kastilahn, A)

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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 7 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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 7 days to

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

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Defendant. The current due date is May 15, 2015. The new due date will be May 22, 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 continuing heavy workload in the last month after a multi-day hearing for

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an Equal Employment Opportunity Commission (EEOC) that occurred in April 2015. In

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addition, since then, in the last two weeks, Defendant was required to work on unanticipated

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matters that could not be assigned to another attorney which required immediate attention,

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including two other EEOC cases that involved developments in settlement negotiations that

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

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occurred this week. 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: May 15, 2015

LAW OFFICES OF BARBARA ARNOLD

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s/ Barbara Arnold by C. Chen*
(As authorized by e-mail on 5/15/2015)
BARBARA ARNOLD
Attorneys for Plaintiff

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Date: May 15, 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: May 18, 2015.

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

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