Felix v. Commissioner of Social Security

Filing 15

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 10/12/2016 ORDERING the Commissioner of Social Security to file a response to the 13 Motion for Summary Judgment by 11/14/2016. (Michel, G.)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT Acting United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CAROLYN B. CHEN, CSBN 256628 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Carolyn.Chen@ssa.gov Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 BRIDGETT JANE MARIE FELIX, Plaintiff, 14 15 16 vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, 17 Defendant. 18 Case No.: 2:16-cv-00698-EFB ) ) ) ) ) ) ) ) ) ) ) ) STIPULATION FOR AN EXTENSION OF TIME OF 30 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 IT IS HEREBY STIPULATED, by and between the parties, through their respective 20 counsel of record, that Defendant shall have an extension of time of an additional 30 days to 21 respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by 22 Defendant. The current due date is October 14, 2016. The new due date will be November 14, 23 2016. 24 There is good cause for this request. Defendant is seeking this extension due to workload 25 issues. Since the filing of Plaintiff’s motion for summary judgment, Defendant’s counsel was 26 limited in her ability to work on this case due to pre-approved leave and two Equal Employment 27 Opportunity Commission (EEOC) cases that had already been extended previously and have 28 Stipulation for an Extension of Time; 2:16-cv-00698-EFB 1 1 briefing deadlines around the same time as the original due date of Defendant’s response to the 2 Plaintiff’s motion for summary judgment for this case. 3 Because of the factors described above, Defendant is requesting additional time up to and 4 including November 14, 2016, to fully review the record and research the issues presented by 5 Plaintiff’s motion for summary judgment. This request is made in good faith with no intention to 6 unduly delay the proceedings. 7 8 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 9 10 Respectfully submitted, Date: October 11, 2016 CERNEY KREUZE & LOTT, LLP 11 s/ Langley Ellen Kreuze by C.Chen* (As authorized by e-mail on 10/7/2016) LANGLEY ELLEN KREUZE Attorneys for Plaintiff 12 13 14 15 Date: October 11, 2016 16 PHILLIP A. TALBERT Acting United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 17 18 Attorneys for Defendant 19 20 21 22 ORDER APPROVED AND SO ORDERED. 23 24 DATED: October 12, 2016 25 _________________________________ HON. EDMUND F. BRENNAN UNITED STATE MAGISTRATE JUDGE 26 27 28 Stipulation for an Extension of Time; 2:16-cv-00698-EFB 2

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