Padlo v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 06/02/16 ORDERING that defendant's date to respond to 16 Motion for Summary Judgment is EXTENDED to 06/30/16. (Benson, A)

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1 2 3 4 5 6 7 8 9 PHILLIP A. TALBERT Acting United States Attorney DEBORAH LEE STACHEL Acting Regional Chief Counsel, Region IX Social Security Administration JENNIFER A. KENNEY, CSBN 241625 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8945 Facsimile: (415) 744-0134 E-Mail: jennifer.a.kenney@ssa.gov Attorneys for Defendant 10 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 ) ) ) ) ) ) ) ) ) ) ) CHARLENE ANN PADLO, 13 14 Plaintiff, 15 vs. 16 CAROLYN W. COLVIN, Acting Commissioner of Social Security, 17 18 Defendant. Case No.: 2:15-CV-01953-AC STIPULATION AND PROPOSED ORDER FOR A FIRST EXTENSION OF 30 DAYS FOR DEFENDANT TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT AND FILE ITS CROSSMOTION FOR SUMMARY JUDGMENT 19 20 21 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s Motion for 22 23 Summary Judgment and file her Cross-Motion for Summary Judgment. This extension is 24 requested because Defendant’s counsel is experiencing an exceptionally busy workload at this 25 time, including three other briefing deadlines before the district court and the Equal Employment 26 Opportunity Commission due the same week as the responsive pleading in this case. The 27 additional time will enable Defendant’s counsel to adequately research the issues presented in 28 this case. The current due date is May 31, 2016. The new due date will be June 30, 2016. Stip. & Prop. Order to Extend 2:15-CV-01953-AC 1 1 2 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 3 4 Respectfully submitted, 5 Dated: May 31, 2016 /s/ Steven Rosales* (*as authorized by email on May 31, 2016) STEVEN ROSALES Attorney for Plaintiff Dated: May 31, 2016 6 PHILLIP A. TALBERT Acting 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/ Jennifer A. Kenney JENNIFER A. KENNEY Special Assistant U.S. Attorney Attorneys for Defendant 16 ORDER 17 18 APPROVED AND SO ORDERED: 19 DATED: June 2, 2016 20 21 22 23 24 25 26 27 28 Stip. & Prop. Order to Extend 2:15-CV-01953-AC 2

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