Olson v. Commissioner of Social Security
Filing
17
STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on 4/3/2017 ORDERING the Commissioner of Social Security to respond to 12 Motion for Summary Judgment by 5/12/2017. (Michel, G.)
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
)
)
)
)
)
)
)
)
)
)
)
)
ALLI K. OLSON,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.
18
Case No.: 2:16-CV-01987-CKD
STIPULATION AND 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 from April
22
3, 2017 to May 12, 2017 due to current workload demands. This is Defendant’s second request
23
for extension. Good cause exists to grant Defendant’s request for extension. Additional time is
24
required as counsel for Defendant has over 45+ active matters, of which five dispositive motions
25
are required on or before the current deadline, including Defendant’s opening brief before the
26
Ninth Circuit. Due to scheduling conflicts, counsel for Defendant needs additional time to
27
complete the agency’s review process and U.S. Attorneys’ process for the Ninth Circuit brief.
28
Additionally, counsel for Defendant was recently assigned a document review matter that
Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD
1
1
requires immediate attention. Defendant respectfully requests additional time to respond to
2
Plaintiff’s Motion for Summary Judgment in order to adequately research, analyze and respond
3
to the issues presented by Plaintiff. Defendant makes this request in good faith with no intention
4
to unduly delay the proceedings. Defendant will diligently meet the new deadline. The parties
5
further stipulate that the Court’s Scheduling Order shall be modified accordingly.
6
7
Respectfully submitted,
8
9
Dated: March 30, 2017
/s/ *Cyrsu Safa
(*as authorized by email on March 30, 2017)
CYRUS SAFA
Attorney for Plaintiff
Dated: March 30, 2017
PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
10
11
12
13
14
15
16
By
17
18
19
20
.
21
22
/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED:
23
24
Dated: April 3, 2017
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
25
26
27
28
Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD
2
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?