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.)

Download PDF
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?