Apel v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 1/23/2017 ORDERING the Commissioner of Social Security to respond to the 18 Motion for Summary Judgment by 3/6/2017; EXTENDING all subsequent deadlines set forth in the Court's Scheduling Order accordingly. (Michel, G.)

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1 2 3 4 5 6 7 8 9 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration TIMOTHY R. BOLIN, CSBN 259511 Special Assistant United States Attorney Social Security Administration Office of the General Counsel 160 Spear St Ste 800 San Francisco, CA 94105 Telephone: (415) 977-8982 Facsimile: (415) 744-0134 Email: timothy.bolin@ssa.gov Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 DAVID IRVING APEL, 15 16 17 18 19 Plaintiff, vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant. ) Case No: 2:16-cv-01022-EFB ) ) STIPULATION AND PROPOSED ORDER ) FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) 20 21 IT IS HEREBY STIPULATED, by and between the parties, through their respective 22 counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary 23 Judgment be extended for 45 days from January 19, 2017 to March 6, 2017. This is Defendant’s 24 first request for an extension of time to respond to Plaintiff’s motion. 25 Defendant requests this extension due to her attorney’s inordinately heavy caseload in 26 January 2017 through February 2017, including an appellate brief before the United States Court 27 of Appeals for the Ninth Circuit and 30 other District Court cases, in a variety of stages, seven of 28 which require imminent briefing in the next three weeks. Defendant’s counsel is also assisting Stip. & Prop. Order for Ext.; 2:16-cv-01022-EFB 1 1 an active employment case before the Equal Employment Opportunity Commission that is in the 2 midst of the discovery process and requires responding to Complainant’s Request for 3 Interrogatories, Admission and Production of Documents by January 23, 2017. Defendant’s 4 counsel respectfully requests this additional time to respond to Plaintiff’s arguments. 5 6 7 The parties further stipulate that all subsequent deadlines set forth in the Court’s Scheduling Order shall be extended accordingly. The parties stipulate in good faith, with no intent to prolong proceedings unduly. 8 Respectfully submitted, 9 10 Dated: January 17, 2017 /s/ Joseph Fraulob* (* As authorized via email on January 17, 2017) JOSEPH FRAULOB 11 12 Attorney for Plaintiff 13 14 Dated: January 17, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 15 16 17 By: 19 /s/ Timothy R. Bolin TIMOTHY R. BOLIN Special Assistant United States Attorney 20 Attorneys for Defendant 18 21 22 Of Counsel to Defendant: BEATRICE NA Assistant Regional Counsel 23 24 25 ORDER APPROVED AND SO ORDERED. 26 27 Dated: January 23, 2017. 28 Stip. & Prop. Order for Ext.; 2:16-cv-01022-EFB __________________________________ THE HONORABLE EDMUND F. BRENNAN United States Magistrate Judge 2

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