Triplett v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 3/10/2017 ORDERING Defendant's time to file a Response to 13 Motion for Summary Judgment is EXTENDED to 4/12/2017. (Washington, S)

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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

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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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JOSEPH B. TRIPLETT,

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Plaintiff,

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vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-cv-02168-KJN
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME OF 35
DAYS FOR DEFENDANT’S RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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

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

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

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Defendant. The current due date is March 8, 2017. The new due date will be April 12, 2017.

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There is good cause for this request. Since the filing of Plaintiff’s motion for summary

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judgment, Defendant’s counsel has been diligently addressing a backlog of cases and heavy

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workload due to her multiple-weeks long absences after two major medical emergencies at the

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end of 2016. In the last week, she also experienced an unanticipated mild medical condition that

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affected her ability to work and required her to be on leave. Despite her diligence and given

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counsel’s continuing heavy workload in the next month, Defendant is requesting additional time

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up to and including April 12, 2017, to fully review the record and research the issues presented

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by Plaintiff’s motion for summary judgment. This request is made in good faith with no

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intention to unduly delay the proceedings.

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

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Respectfully submitted,
Date: March 8, 2017

LAW OFFICES OF LAWRENCE D. ROHLFING

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s/ Young Cho by C.Chen*
(As authorized by e-mail on 3/8/2017)
YOUNG CHO
Attorneys for Plaintiff

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Date: March 8, 2017

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

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Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED:

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Dated: March 10, 2017

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