Gummeson v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 4/27/17 ORDERING that plaintiff's reply brief is DUE on 5/5/2017. (Kastilahn, A)

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Jonathan O. Peña, Esq.
CA Bar ID No.: 278044
Peña & Bromberg, PLC
5740 N. Palm Avenue
Suite 103
Fresno, CA 93704
Telephone: [phone]
Facsimile:866-282-6709
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CONNIE LYNN GUMMESON,
Plaintiff,
vs.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-CV-01611-CKD
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME FOR PLAINTIFF TO
FILE HER REPLY BRIEF

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that Plaintiff shall have a short extension of time of seven (7) days to respond to Defendant’s

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Response to Plaintiff’s Motion for Summary Judgment. This is Plaintiff’s first request for

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extension to file her Reply Brief. Plaintiff’s Reply Brief is currently due on April 28, 2017; if

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this request is granted, Plaintiff’s Reply Brief will be due on May 5, 2017.

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There is good cause for this request. Plaintiff’s counsel has long been committed to two

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events in the last week of April and first week of May, the first of which requires him to travel to

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Extension of Time Stipulation, (Case # 2:16-CV-01611-CKD )

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Florida and the second to Minnesota. In anticipation, Plaintiff’s counsel has been diligently

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reviewing, drafting and finalizing the memoranda and pleadings that are due during this time.

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Defendant submitted its brief on April 10; while Plaintiff’s counsel has reviewed the brief and

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intends to file a reply, Plaintiff’s counsel believes that the complexities of the matter require him

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to devote additional time to the Reply brief in order to fully present the issues to the Court. This

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is unfeasible due to Plaintiff’s counsel’s travel and training schedule; as such, Plaintiff

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respectfully requests a short extension in order to present a comprehensive and fully developed

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

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

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accordingly.
Respectfully submitted,

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Dated: April 26, 2017

/s/ Jonathan Omar Pena
JONATHAN OMAR PENA
Law Office of Jonathan O. Pena
Attorney for Plaintiff

Dated: April 26, 2017

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

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By:

/s/ Carolyn B. Chen
(*as authorized by email on 4/25/17)
CAROLYN B. CHEN
Special Assistant U.S. Attorney
Attorneys for Defendant

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Extension of Time Stipulation, (Case # 2:16-CV-01611-CKD )

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ORDER

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APPROVED AND SO ORDERED:
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Dated: April 27, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Extension of Time Stipulation, (Case # 2:16-CV-01611-CKD )

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