Gummeson v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 3/9/17 ORDERING that the date for defendant to respond to plaintiff's Motion for Summary Judgment is EXTENDED to 04/07/17. (Kaminski, H)

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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

SACRAMENTO DIVISION

12
13
14
15
16
17
18

CONNIE LYNNE GUMMESON,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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

Case No.: 2:16-cv-01611-CKD
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 35 DAYS FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

19
20

IT IS HEREBY STIPULATED, by and between the parties, through their respective

21

counsel of record, that Defendant shall have an extension of time of an additional 35 days to

22

respond to Plaintiff’s motion for summary judgment. This is the second continuance sought by

23

Defendant. The current due date is March 3, 2017. The new due date will be April 7, 2017.

24

There is good cause for this request. Since Defendant’s previous request, Defendant’s

25

counsel has been diligent in addressing a backlog of cases and heavy workload due to her

26

multiple-weeks long absences after two medical emergencies. In the last week, she also

27

experienced an unanticipated mild medical condition that affected her ability to work and

28

required her to be on leave. Despite her diligence and given counsel’s heavy workload in the

1

1

next month, Defendant is requesting additional time up to and including April 7, 2017, to fully

2

review the record and research the issues presented by Plaintiff’s motion for summary judgment.

3

This request is made in good faith with no intention to unduly delay the proceedings.

4
5

The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

6
7

Respectfully submitted,
Date: March 6, 2017

PEÑA & BROMBERG, PLC

8
s/ Jonathan O. Peña by C.Chen*
(As authorized by e-mail on 3/6/2017)
JONATHAN O. PEÑA, ESQ.
Attorneys for Plaintiff

9
10
11
12

Date: March 6, 2017

13

PHILLIP A. TALBERT
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

14
15

Attorneys for Defendant

16
17
18
19

ORDER
APPROVED AND SO ORDERED:

20
21
22

Dated: March 9, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

23
24
25
26
27
28

2