Doran v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER 22 for extension of time signed by Magistrate Judge Craig M. Kellison on 2/19/2016. Defendant has up to and including 3/24/2016 to respond to plaintiff's 21 Motion for Summary Judgment. (Marciel, M)

1
2
3
4
5
6
7

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

8
9

Attorneys for Defendant

10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA

12
13

KATHLEEN P. DORAN,

14
15
16

Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

17
Defendant.

18

) Case No.: 2:15-cv-00777-CMK
)
) 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 Defendant to respond to Plaintiff’s Motion for Summary

22

Judgment be extended 35 days to and including March 24, 2016. This is Defendant’s first

23

request for an extension of time to respond to Plaintiff’s motion. Defense counsel needs the

24

additional time to further review the file and prepare a response in this matter due to a heavy

25

workload, including several other district court cases, despite due diligence.

26

///

27
28

1
2
3

The parties further stipulate that the remaining dates in the Court’s Scheduling Order
shall be modified accordingly.
Defense counsel apologizes to the Court for any inconvenience caused by this delay.

4
Respectfully submitted,

5
6

Dated: February 17, 2016

/s/ Lynn M. Harada for Jacqueline Forslund*_
(*as authorized via email on 2/16/16)
JACQUELINE FORSLUND
Attorney for Plaintiff

Dated: February 17, 2016

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

7
8
9
10
11
12
13
By:

15

/s/ Lynn M. Harada
LYNN M. HARADA
Special Assistant U.S. Attorney

16

Attorneys for Defendant

14

17
18
ORDER:

19
20

APPROVED AND SO ORDERED:

21

Dated: February 19, 2016

22
23
24
25
26
27
28