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.)

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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: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov 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

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