Madkins v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 8/25/15 re: 16 APPROVING AND ORDERING defendant an extension of time of an additional 30 days to respond to plaintiff's opening brief. The new due date will be 9/25/15. (Meuleman, A)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
CHANTAL R. JENKINS, PA SBN 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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KIMBERLY Y. MADKINS,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

) Case No.: 2:14-CV-02750-EFB
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) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
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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 opening brief. The current due date is August 26, 2015. The new due date
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will be September 25, 2015. This is Defendant’s first request for an extension.
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Defendant respectfully requests this additional time because Defendant’s counsel is
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managing a heavy caseload. Defendant’s counsel is currently responsible for managing and
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briefing forty-one other matters pending before the District Courts. Defendant’s counsel has
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completed five such briefs since Plaintiff filed her opening brief. Counsel is also in the process
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Stipulation and Proposed Order for an Extension of Time; 2:14-cv-02750-EFB

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of completing a ninth circuit appellate brief, which must be reviewed by the Office of General

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Counsel and the United States Department of Justice (DOJ). In addition, counsel is representing

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the agency in a federal employment discrimination case and is in the process of gathering and

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serving documents for discovery.

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This request is made in good faith with no intention to unduly delay the proceedings.

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

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accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: August 24, 2015

/s/_Jared Walker by Chantal R. Jenkins*__
As authorized via email on August 24, 2015
JARED T. WALKER
Attorney for Plaintiff

Dated: August 24, 2015

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

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ORDER

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APPROVED AND SO ORDERED.
Dated: August 25, 2015.

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Stipulation and Proposed Order for an Extension of Time; 2:14-cv-02750-EFB