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)

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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: (415) 977-8977 Facsimile: (415) 744-0134 E-Mail: Lynn.Harada@ssa.gov 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

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