Rodriguez v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 9/14/15 ORDERING that Defendant shall have an extension of time of an additional 30 days to respond to Plaintiff's opening brief. The current due date is September 16, 2015. The new due date will be October 16, 2015. (Becknal, R)

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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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DEBORAH ANNA RODRIGUEZ,
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Plaintiff,
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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:15-cv-00231-CKD
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S BRIEF

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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 September 16, 2015. The new due
date will be October 16, 2015. This is Defendant’s first request for an extension.
Defendant respectfully requests this additional time because Defendant’s counsel is
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. Counsel is also in the
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process of completing a ninth circuit appellate brief, which must be reviewed by the Office of
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Stipulation and Proposed Order for an Extension of Time; 2:15-cv-00231-CKD

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

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

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gathering and 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: September 10, 2015

/s/_Jesse S. Kaplan by Chantal R. Jenkins*__
As authorized via email on September 10, 2015
JESSE S. KAPLAN
Attorney for Plaintiff

Dated: September 10, 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: September 14, 2015

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Proposed Order for an Extension of Time; 2:15-cv-00231-CKD

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