Winkelman v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 4/12/2017 ORDERING the plaintiff to file a Motion for Summary Judgment by 5/1/2017. (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 BEATRICE NA, CSBN 303390 Special Assistant United States Attorney Social Security Administration Office of the General Counsel 160 Spear St Ste 800 San Francisco, CA 94105 Telephone: (415) 977-8967 Facsimile: (415) 744-0134 E-mail: Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 RAY JACHIN WINKELMAN, 15 16 17 18 19 Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) Case No. 2:16-cv-01126-AC ) ) JOINT 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 deadline for Plaintiff’s Motion for Summary Judgment be extended from 23 April 14, 2017 to May 1, 2017. 24 The parties request this extension because Plaintiff had inquired that there may be some 25 medical evidence missing from the Certified Administrative Record (CAR). Accordingly, 26 Defendant’s counsel has contacted and requested Office of Disability Adjudication and Review 27 (ODAR), the agency component responsible for producing the CAR, to investigate whether there 28 is any medical evidence missing from the CAR and if so, to produce supplemental CAR. Upon Joint Stip. & Prop. Order for Ext.; 2:16-cv-1126-AC 1 1 investigation, ODAR has informed Defendant’s counsel that there is no medical evidence that 2 has not been included in the CAR already produced and filed with the Court, and that the CAR is 3 the complete record. Because the inquiry and investigation process consumed some time 4 following Defendant’s filing of answer, the parties respectfully request additional time for 5 Plaintiff to prepare his motion for summary judgment. 6 7 8 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. 9 Respectfully submitted, 10 Dated: April 11, 2017 /s/ Robert C. Weems* (* As authorized via email on April 11, 2017) ROBERT C. WEEMS 11 12 Attorney for Plaintiff 13 14 15 Dated: April 11, 2017 PHILLIP A. TALBERT United States Attorney 16 By: 17 18 /s/ Beatrice Na BEATRICE NA Special Assistant United States Attorney Attorneys for Defendant 19 20 21 ORDER 22 23 DATED: April 12, 2017. 24 25 26 27 28 Joint Stip. & Prop. Order for Ext.; 2:16-cv-1126-AC 2

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