Ortiz v. Commissioner of SSA

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 12/14/15 ordering the time for responding to plaintiff's motion for summary judgment be extended from 12/30/15 to 2/01/16. (Plummer, M)

1
2
3
4
5
6
7
8
9

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
ROYA MASSOUMI, CSBN 242697
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

10

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

11

SACRAMENTO DIVISION

12

)
)
)
)
)
)
)
)
)
)
)

CHERISH FAWN ORTIZ,

13
14
15
16
17
18

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

Case No.: 2:15-CV-01456-AC
STIPULATION AND PROPOSED ORDER
FOR EXTENSION OF TIME FOR
DEFENDANT TO FILE OPPOSITION TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

19
20
21

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

22

that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from

23

December 30, 2015, to February 1, 2016. This is Defendant’s first request for extension.

24

Defendant respectfully requests additional time following recent reassignment of the case in

25

order to adequately research and analyze the issues presented by Plaintiff. Defendant makes this

26

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

27
28

Stip. & Prop. Order to Extend 2:15-CV-01456-AC

1

1
2

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

3
4

Respectfully submitted,

5
6

Dated: December 10, 2015

/s/ *John v. Johnson
(*as authorized by email on December 5, 2015)
JOHN V. JOHNSON
Attorney for Plaintiff

Dated: December 10, 2015

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:

14
15

/s/ Roya Massoumi
ROYA MASSOUMI
Special Assistant U.S. Attorney
Attorneys for Defendant

16
ORDER

17
18

APPROVED AND SO ORDERED:

19
20

DATED: December 14, 2015

21
22
23
24
25
26
27
28

Stip. & Prop. Order to Extend 2:15-CV-01456-AC

2