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.)

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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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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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ALLI K. OLSON,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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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

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from April

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3, 2017 to May 12, 2017 due to current workload demands. This is Defendant’s second request

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for extension. Good cause exists to grant Defendant’s request for extension. Additional time is

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required as counsel for Defendant has over 45+ active matters, of which five dispositive motions

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are required on or before the current deadline, including Defendant’s opening brief before the

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Ninth Circuit. Due to scheduling conflicts, counsel for Defendant needs additional time to

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complete the agency’s review process and U.S. Attorneys’ process for the Ninth Circuit brief.

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Additionally, counsel for Defendant was recently assigned a document review matter that
Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD

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requires immediate attention. Defendant respectfully requests additional time to respond to

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Plaintiff’s Motion for Summary Judgment in order to adequately research, analyze and respond

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to the issues presented by Plaintiff. Defendant makes this request in good faith with no intention

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to unduly delay the proceedings. Defendant will diligently meet the new deadline. The parties

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

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Respectfully submitted,

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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

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER
APPROVED AND SO ORDERED:

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Dated: April 3, 2017

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Joint Stipulation for Extension of Time; 2:16-CV-01987-CKD

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