Mann v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 10/31/2016 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED to 12/21/2016. (Zignago, K.)

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1 2 3 4 5 6 7 8 9 BENJAMIN B.WAGNER United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CYNTHIA B. DE NARDI, CSBN 256770 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8961 Facsimile: (415) 744-0134 Email: cynthia.denardi@ssa.gov Attorneys for Defendant 10 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION 11 12 13 14 15 16 17 18 ) Case No. 2:16-cv-00421-AC ) ) STIPULATION AND PROPOSED ORDER ) FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) ) LOURA LEE MANN, Plaintiff, v. CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant. 19 20 21 22 23 24 25 26 27 IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that the time for responding to Plaintiff’s Motion for Summary Judgment (Doc. 14) be extended from November 21, 2016, to December 21, 2016. This is Defendant’s first request for an extension of time to respond to Plaintiff’s motion. Defendant respectfully requests this additional time because Defendant’s counsel has four Federal court pleadings to prepare before November 21, 2016, and a post-hearing brief in a Merit Systems Protection Board original jurisdiction case which is due on November 25, 2016, the Friday of the Thanksgiving holiday week. 28 Stip. & Prop. Order for Ext.; 2:16-cv00421-AC -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 6 Respectfully submitted, Dated: October 27, 2016 7 8 9 BENJAMIN B. WAGNER United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 10 11 12 13 /s_Robert Weems*_____________________________________ (*as authorized via email on 10/27/16) ROBERT WEEMS Attorney for Plaintiff Dated: October 27, 2016 14 15 By: /s/ Cynthia B. De Nardi CYNTHIA B. DE NARDI Special Assistant United States Attorney Attorneys for Defendant 16 17 18 19 20 ORDER 21 APPROVED AND SO ORDERED: 22 Dated: October 31, 2016 23 24 25 26 27 28 Stip. & Prop. Order for Ext.; 2:16-cv00421-AC -2-

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