Hagan v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 5/13/15 ORDERING that the time for defendant to respond to plaintiff's Motion for Summary Judgment is EXTENDED to 6/12/15. (Kastilahn, A)

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1 2 3 4 5 6 7 BENJAMIN B. WAGNER United States Attorney DONNA CALVERT Regional Chief Counsel, Region IX Social Security Administration JACOB M. MIKOW, CSBN 238045 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, CA 94105 Telephone: 415-977-8976 Fax: 415-744-0134 Jacob.Mikow@ssa.gov 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 SHANNON RENEE HAGAN, 13 Plaintiff, 14 vs. 15 16 17 CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant. 18 ) Case No.: 2:14-cv-02464-EFB ) ) STIPULATION AND PROPOSED ORDER ) FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) 19 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 May 13, 2015 to June 12, 2015. This is Defendant’s first request for an extension 23 of time to respond to Plaintiff’s motion. An extension of time is needed given Defense counsel’s 24 workload, and in order for counsel to review and respond to the issues raised in Plaintiff’s 25 motion. The parties further stipulate that the Court’s Scheduling Order shall be modified 26 accordingly. 27 Counsel apologizes to the Court for any inconvenience caused by this delay. 28 Stip. & Prop. Order for Ext.; 2:14-cv-02464-EFB 1 1 Respectfully submitted, /s/ Joseph C. Fraulob_____ (As authorized via email on 5/11/2015) JOSEPH C. FRAULOB Attorney for Plaintiff Dated: 5/11/2015 2 3 4 5 Dated: 5/11/2015 BENJAMIN B. WAGNER United States Attorney DONNA CALVERT Regional Chief Counsel, Region IX Social Security Administration 6 7 8 By: 9 10 11 /s/ Jacob M. Mikow JACOB M. MIKOW Special Assistant United States Attorney Attorneys for Defendant OF COUNSEL: 12 13 In Seon Jeong Assistant Regional Counsel 14 15 16 ORDER 17 18 19 APPROVED AND SO ORDERED. Dated: May 13, 2015. 20 21 22 23 24 25 26 27 28 Stip. & Prop. Order for Ext.; 2:14-cv-02464-EFB 2

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