Torres v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 4/6/2017 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED to 4/14/2017. (Zignago, K.)

7

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

8

Attorneys for Defendant

1
2
3
4
5
6

9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

SACRAMENTO DIVISION

12
13
14
15
16
17

)
)
)
)
)
)
)
)
)
)
)
)

ENRIQUE TORRES,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

18

Case No.: 2:16-cv-01574-EFB
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME FOR DEFENDANT TO FILE
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

19
20

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

21

that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for four

22

days from April 10, 2017, to April 14, 2017. This is Defendant’s second request for extension.

23

Good cause exists as counsel for Defendant has a pending Ninth Circuit brief to finalize and two

24

back-to-back dispositive motions to file thereafter before the current deadline. Defendant

25

respectfully requests additional time to respond to Plaintiff’s Motion for Summary Judgment in

26

order to adequately research and analyze the issues presented by Plaintiff. In addition,

27

Defendant would like some additional time to explore the issues to determine if this case is

28

Joint Stipulation and PO for Extension of Time; 2:16-cv-01574-EFB

1

1

suitable for remand. Defendant makes this request in good faith with no intention to unduly

2

delay the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be

3

modified accordingly.

4
5

Respectfully submitted,

6
7

Dated: April 4, 2017

/s/ *Jacqueline Forslund
(*as authorized by email on April 2, 2017)
JACQUELINE FORSLUND
Attorney for Plaintiff

Dated: April 4, 2017

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

8
9
10
11
12
13
14
By

15
16
17
18

/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER

19
20
21

APPROVED AND SO ORDERED.
DATED: April 6, 2017.

22
23
24
25
26
27
28

Joint Stipulation and PO for Extension of Time; 2:16-cv-01574-EFB

2