Winkelman v. Commissioner of Social Security

Filing 22

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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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: beatrice.na@ssa.gov 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 Defendant’s time for responding to Plaintiff’s Motion for Summary 23 Judgment be extended from July 14, 2017 to August 30, 2017. This is Defendant’s first request 24 for an extension of time to respond to Plaintiff’s Motion for Summary Judgment. 25 Defendant requests this extension due to her counsel’s heavy workload. Defendant’s 26 counsel is responsible for an appellate brief for a Social Security case in the United States Court 27 of Appeals for the Ninth Circuit, discovery in two personnel-related litigations pending before 28 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 1 1 District Courts for the Northern District, Eastern District, Central District, and Southern District 2 of California, and District of Nevada. Defendant’s counsel respectfully requests this time to 3 review the Administrative Record, and to evaluate and respond to issues Plaintiff raises in his 4 motion. 5 The parties further stipulate that all subsequent deadlines shall be extended accordingly. 6 The parties stipulate in good faith, with no intent to prolong proceedings unduly. 7 Respectfully submitted, 8 Dated: July 12, 2017 /s/ Beatrice Na for Robert C. Weems* (* As authorized via email on July 12, 2017) ROBERT C. WEEMS 9 10 Attorney for Plaintiff 11 12 13 Dated: July 12, 2017 PHILLIP A. TALBERT United States Attorney 14 By: 15 16 /s/ Beatrice Na BEATRICE NA Special Assistant United States Attorney Attorneys for Defendant 17 18 19 ORDER 20 21 22 23 APPROVED AND SO ORDERED: Dated: July 13, 2017 24 25 26 27 28 Joint Stip. & Prop. Order for Ext.; 2:16-cv-1126-AC 2

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