Winkelman v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 7/13/2017 ORDERING that Defendant's time for responding to Plaintiff's Motion for SummaryJudgment is extended from July 14, 2017 to August 30, 2017. (Becknal, R)
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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: beatrice.na@ssa.gov
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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RAY JACHIN WINKELMAN,
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Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.
) Case No. 2:16-cv-01126-AC
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) JOINT 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 from July 14, 2017 to August 30, 2017. This is Defendant’s first request
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for an extension of time to respond to Plaintiff’s Motion for Summary Judgment.
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Defendant requests this extension due to her counsel’s heavy workload. Defendant’s
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counsel is responsible for an appellate brief for a Social Security case in the United States Court
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of Appeals for the Ninth Circuit, discovery in two personnel-related litigations pending before
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the Equal Employment Opportunity Commission (EEOC), and over 40 cases in the United States
Joint Stip. & Prop. Order for Ext.; 2:16-cv-1126-AC
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District Courts for the Northern District, Eastern District, Central District, and Southern District
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of California, and District of Nevada. Defendant’s counsel respectfully requests this time to
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review the Administrative Record, and to evaluate and respond to issues Plaintiff raises in his
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motion.
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The parties further stipulate that all subsequent deadlines shall be extended accordingly.
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The parties stipulate in good faith, with no intent to prolong proceedings unduly.
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Respectfully submitted,
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Dated: July 12, 2017
/s/ Beatrice Na for Robert C. Weems*
(* As authorized via email on July 12, 2017)
ROBERT C. WEEMS
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Attorney for Plaintiff
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Dated: July 12, 2017
PHILLIP A. TALBERT
United States Attorney
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By:
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/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney
Attorneys for Defendant
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ORDER
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APPROVED AND SO ORDERED:
Dated: July 13, 2017
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Joint Stip. & Prop. Order for Ext.; 2:16-cv-1126-AC
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