Johnson v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 3/27/17: Defendant shall have an extension of time to April 3, 2017 to respond to Plaintiff's opening brief. (Kaminski, H)

1
2
3
4
5
6
7

PHILLIP A. TALBERT
United States Attorney
DEBORAH STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
Chantal R. Jenkins, SBN PA 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

8
9

Attorneys for Defendant
UNITED STATES DISTRICT COURT

10
EASTERN DISTRICT OF CALIFORNIA
11
SACRAMENTO DIVISION
12
13

) Case No.: 2:16-cv-01025-AC
)
) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
)
)
)
)
)
)
)
)

LAURA J. JOHNSON,
14
Plaintiff,
15
16
17

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

18
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 to April 3, 2017 to respond to
22
Plaintiff’s opening brief. This is Defendant’s first request for an extension of time. Defendant’s
23
counsel did not realize that Plaintiff had filed her opening brief and apologizes for the delay in
24
submitting the brief or an extension request by the due date, March 1, 2017.
25
This request is made in good faith with no intention to unduly delay the proceedings.
26
The parties further stipulate that the Court’s Scheduling Order shall be modified
27
accordingly.
28
Stipulation and Proposed Order for Extension of Time; 2:16-cv-01025-AC

1

1

Counsel apologizes to the Court for any inconvenience caused by this delay.

2
3
4

Respectfully submitted,
Dated: March 23, 2017

/s/ Robert Weems by Chantal R. Jenkins*
Robert Weems
As authorized via email by Robert Weems
on March 23, 2017
Attorney for Plaintiff

Dated: March 23, 2017

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

5
6
7
8
9
10
11
12
By:

13
14

/s/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

15
16

ORDER

17
18

APPROVED AND SO ORDERED:

19
20

Dated: March 27, 2017

21
22
23
24
25
26
27
28
Stipulation and Proposed Order for Extension of Time; 2:16-cv-01025-AC

2