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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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: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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DAVID IRVING APEL,

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Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

) Case No: 2:16-cv-01022-EFB
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) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary

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Judgment be extended for 45 days from January 19, 2017 to March 6, 2017. This is Defendant’s

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first request for an extension of time to respond to Plaintiff’s motion.

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Defendant requests this extension due to her attorney’s inordinately heavy caseload in

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January 2017 through February 2017, including an appellate brief before the United States Court

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of Appeals for the Ninth Circuit and 30 other District Court cases, in a variety of stages, seven of

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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

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an active employment case before the Equal Employment Opportunity Commission that is in the

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midst of the discovery process and requires responding to Complainant’s Request for

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Interrogatories, Admission and Production of Documents by January 23, 2017. Defendant’s

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counsel respectfully requests this additional time to respond to Plaintiff’s arguments.

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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.

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Respectfully submitted,

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Dated: January 17, 2017

/s/ Joseph Fraulob*
(* As authorized via email on January 17, 2017)
JOSEPH FRAULOB

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Attorney for Plaintiff

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Dated: January 17, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney

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Attorneys for Defendant

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Of Counsel to Defendant:
BEATRICE NA
Assistant Regional Counsel

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ORDER
APPROVED AND SO ORDERED.

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Dated: January 23, 2017.

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Stip. & Prop. Order for Ext.; 2:16-cv-01022-EFB

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THE HONORABLE EDMUND F. BRENNAN
United States Magistrate Judge

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