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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1 2 3 4 5 6 7 8 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: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 JOSEPH B. TRIPLETT, 14 Plaintiff, 15 16 17 18 vs. CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) 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 19 20 IT IS HEREBY STIPULATED, by and between the parties, through their respective 21 counsel of record, that Defendant shall have an extension of time of an additional 35 days to 22 respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by 23 Defendant. The current due date is March 8, 2017. The new due date will be April 12, 2017. 24 There is good cause for this request. Since the filing of Plaintiff’s motion for summary 25 judgment, Defendant’s counsel has been diligently addressing a backlog of cases and heavy 26 workload due to her multiple-weeks long absences after two major medical emergencies at the 27 end of 2016. In the last week, she also experienced an unanticipated mild medical condition that 28 affected her ability to work and required her to be on leave. Despite her diligence and given 1 1 counsel’s continuing heavy workload in the next month, Defendant is requesting additional time 2 up to and including April 12, 2017, to fully review the record and research the issues presented 3 by Plaintiff’s motion for summary judgment. This request is made in good faith with no 4 intention to unduly delay the proceedings. 5 6 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 7 8 Respectfully submitted, Date: March 8, 2017 LAW OFFICES OF LAWRENCE D. ROHLFING 9 s/ Young Cho by C.Chen* (As authorized by e-mail on 3/8/2017) YOUNG CHO Attorneys for Plaintiff 10 11 12 13 Date: March 8, 2017 14 PHILLIP A. TALBERT United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 15 16 Attorneys for Defendant 17 18 19 20 ORDER APPROVED AND SO ORDERED: 21 22 Dated: March 10, 2017 23 24 25 26 27 28 2

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