Gnibus v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 4/27/16 ORDERING that Defendant shall have an extension of time to 5/4/2016 to respond to Plaintiff's opening brief. (Kastilahn, A)

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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 Chantal R. Jenkins, SBN PA 307531 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8931 Facsimile: (415) 744-0134 E-Mail: Chantal.Jenkins@ssa.gov 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 LYNN EILEEN GNIBUS, 14 Plaintiff, 15 16 17 18 19 vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant. ) Case No.: 2:15-CV-01669-AC ) ) STIPULATION AND PROPOSED ORDER ) FOR A SECOND EXTENSION OF TIME ) ) ) ) ) ) ) ) 20 IT IS HEREBY STIPULATED, by and between the parties, through their respective 21 counsel of record, that Defendant shall have an extension of time to May 4, 2016 to respond to 22 Plaintiff’s opening brief. The current due date is April 20, 2016. Defendant respectfully 23 requests this additional time due to a heavy workload. Defendant’s counsel just argued before 24 the Ninth Circuit and is currently working on a motion in another matter before the Ninth 25 Circuit. In addition, Defendant’s counsel is responsible for managing and briefing forty-eight 26 other matters pending before the District Courts. 27 This request is made in good faith with no intention to unduly delay the proceedings. 28 1 1 2 3 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. Counsel apologizes to the Court for any inconvenience caused by this delay. 4 5 Respectfully submitted, 6 LAW OFFICES OF LAWRENCE D. ROHLFING 7 Dated: April 19, 2016 /s/ Vijay J. Patel by Chantal R. Jenkins* Vijay J. Patel As authorized via email on April 19, 2016 Attorney for Plaintiff Dated: April 19, 2016 BENJAMIN B. WAGNER United States Attorney DEBORAH LEE STACHEL Acting Regional Chief Counsel, Region IX Social Security Administration 8 9 10 11 12 13 14 15 By: 16 /s/ Chantal R. Jenkins CHANTAL R. JENKINS Special Assistant United States Attorney 17 18 ORDER 19 20 APPROVED AND SO ORDERED: 21 22 Dated: April 27, 2016 23 24 25 26 27 28 2

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