Uhler v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 1/20/2017 ORDERING the Commissioner of Social Security to respond to the 10 Motion for Summary Judgment by 1/19/2017; ORDERING that the Court's Scheduling Order be modified accordingly. (Michel, G.)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CAROLYN B. CHEN, CSBN 256628 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Carolyn.Chen@ssa.gov Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 THERESA ANN UHLER, Plaintiff, 14 15 16 vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, 17 Defendant. 18 Case No.: 2:16-cv-01255-EFB ) ) ) ) ) ) ) ) ) ) ) ) STIPULATION FOR AN EXTENSION OF TIME OF 2 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT IT IS HEREBY STIPULATED, by and between the parties, through their respective 19 20 counsel of record, that Defendant shall have an extension of time of an additional 2 days to 21 respond to Plaintiff’s motion for summary judgment. This is the second continuance sought by 22 Defendant. The current due date is January 17, 2017. The new due date will be January 19, 23 2017. 24 There is good cause for this request. As stated in Defendant’s previous request, 25 Defendant requested an extension for Defendant’s counsel’s emergency and workload issues, 26 including recovering and catching up on her workload from a medical emergency on Monday, 27 October 24, 2016. In addition, Defendant’s counsel was rear-ended in a car accident in 28 1 1 December caused by another driver, and had to take more leave than originally anticipated to 2 recover from her injuries and returned to the office on January 9, 2017. 3 Because of the factors described above, Defendant is requesting additional time up to and 4 including January 19, 2017, to fully review the record and research the issues presented by 5 Plaintiff’s motion for summary judgment, as Defendant’s counsel recovers and addresses her 6 workload upon her return. This request is made in good faith with no intention to unduly delay 7 the proceedings. 8 9 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 10 11 Respectfully submitted, Date: January 17, 2017 CAMPBELL & CLARK 12 s/ Robert N. Campbell by C.Chen* (As authorized by e-mail on 1/17/2017) ROBERT N. CLARK Attorneys for Plaintiff 13 14 15 16 Date: January 17, 2017 17 PHILLIP A. TALBERT United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 18 19 Attorneys for Defendant 20 21 22 23 ORDER APPROVED AND SO ORDERED. 24 25 26 DATED: January 20, 2017. _________________________________ HON. EDMUND F. BRENNAN UNITED STATE MAGISTRATE JUDGE 27 28 2

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