Vasquez v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER granting 21 Motion for Extension of time signed by Magistrate Judge Craig M. Kellison on 5/25/17. (Kaminski, H)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT 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: Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 FRANCISCO ROBERTO VASQUEZ, 14 Plaintiff, 15 16 vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, 17 Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-cv-00941-CMK MOTION FOR AN EXTENSION OF TIME OF 21 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 Defendant, through her counsel of record, moves for an extension of time of an additional 20 21 21 days to respond to Plaintiff’s motion for summary judgment. This is the second continuance 22 sought by Defendant. The current due date is May 26, 2017. The new due date will be June 16, 23 2017. 24 There is good cause for this request. Since the filing of Plaintiff’s motion for summary 25 judgment, in the last few days, Defendant’s counsel has come down with flu-like symptoms 26 which will keep her from filing Defendant’s response to Plaintiff’s Motion for Summary 27 Judgment timely. Furthermore, in the next few weeks, Defendant’s counsel has pre-approved 28 leave and a continuing full workload of about seven pending District Court briefs and one district 1 1 court hearing to address. Therefore, Defendant is respectfully requesting additional time up to 2 and including June 16, 2017, to fully review the record and research the issues presented by 3 Plaintiff’s motion for summary judgment, as Defendant’s counsel recovers from her sickness and 4 addresses her workload. This request is made in good faith with no intention to unduly delay the 5 proceedings. 6 Defendant moves that the Court’s Scheduling Order shall be modified accordingly. 7 On May 23, 2017, Defendant reached out to Plaintiff through his counsel Steven Rosales 8 of Law Offices of Lawrence D. Rohlfing, and Plaintiff through his counsel confirmed on May 9 24, 2017 that he had no objection to the motion. 10 11 12 Respectfully submitted, Date: May 24, 2017 13 14 PHILLIP A. TALBERT United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 15 16 Attorneys for Defendant 17 18 ORDER 19 20 APPROVED AND SO ORDERED: 21 22 Dated: May 25, 2017 23 24 25 26 27 28 2

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