Vasquez v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 6/16/2017 ORDERING Defendant to respond to 18 Motion for Summary Judgment by 6/30/2017. (Washington, S)

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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 17 18 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-cv-00941-CMK STIPULATION AND ORDER FOR AN EXTENSION OF TIME OF 14 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 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 of an additional 14 days to 22 respond to Plaintiff’s motion for summary judgment. This is the third continuance sought by 23 Defendant. The current due date is June 16, 2017. The new due date will be June 30, 2017. 24 There is good cause for this request. Since the Court’s order of extension dated May 25, 25 2017, Defendant’s counsel has been recovering from and diligently addressing a backlog of cases 26 and her full workload after her absence from sickness with flu-like symptoms and pre-approved 27 leave. Furthermore, Defendant’s counsel continues to have a full workload in the next couple of 28 weeks and beyond, specifically including one district court oral argument and an Equal 1 1 Employment Opportunity Commission matter involving discovery that was just assigned to 2 Defendant’s counsel this week as an emergency and that could not be assigned to another 3 attorney. Therefore, Defendant is respectfully requesting additional time up to and including 4 June 30, 2017, to fully review the record and research the issues presented by Plaintiff’s motion 5 for summary judgment, as Defendant’s counsel prioritizes this case amongst her new and 6 unanticipated pressing immediate deadlines. This request is made in good faith with no intention 7 to unduly delay the proceedings. 8 9 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 10 11 Respectfully submitted, Date: June 14, 2017 LAW OFFICES OF LAWRENCE D. ROHLFING 12 s/ Steven G. Rosales by C.Chen* (As authorized by e-mail on 6/14/2017) STEVEN G. ROSALES Attorneys for Plaintiff 13 14 15 16 Date: June 14, 2017 17 PHILLIP A. TALBERT United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 18 19 Attorneys for Defendant 20 21 ORDER 22 23 APPROVED AND SO ORDERED: 24 Dated: June 16, 2017 25 26 27 28 2

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