Haun v. Commissioner of Social Security

Filing 11

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 1/4/2017 ORDERING that defendant shall respond to the complaint and serve a certified copy of the transcript of the administrative record on or before 2/2/2017. Plaintiff shall serve new evidence and/or a confidential settlement letter to Defendant on or before 3/6/2017. Defendant shall serve her response to Plaintiff's confidential settlement letter on or before 4/5/2017. In the event the parties do not agree to remand, Plaintiff shall file her motion for summary judgment on or before 5/10/2017. Defendant shall file her response to Plaintiff's motion for summary judgment on or before 6/9/2017. Plaintiff shall file any reply on or before 6/29/2017. (Zignago, K.)

1
2
3
4
5

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
California State Bar No. 263027
Special Assistant United States Attorney

6
7
8
9
10

160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
ATTORNEYS FOR DEFENDANT

11
12

UNITED STATES DISTRICT COURT

13

EASTERN DISTRICT OF CALIFORNIA

14

SACRAMENTO DIVISION

15

)
)
)
)
)
)
)
)
)
)
)
)
)

16

LISA A. HAUN,

17

Plaintiff,

18

vs.

19
20

CAROLYN W. COLVIN, Acting Commissioner
Of Social Security,

CIVIL NO. 2:16-cv-02190-AC
STIPULATION AND PROPOSED
ORDER FOR DEFENDANT’S FIRST
EXTENSION OF TIME TO RESPOND
TO COMPLAINT AND SERVE A
CERTIFIED COPY OF THE
TRANSCRIPT OF THE
ADMINISTRATIVE RECORD

21

Defendant.

22

IT IS HEREBY STIPULATED, by and between Lisa A. Haun (Plaintiff) and Carolyn W.

23

Colvin, Acting Commissioner of Social Security (Defendant or the Commissioner), by and through

24

their respective counsel of record, that Defendant shall have an extension of time of 30 days to respond

25

to the complaint filed in the above-captioned matter (Docket Number 1) and serve a certified copy of

26

the transcript of the administrative record pursuant to the Court’s September 19, 2016 Procedural Order

27

for Social Security Review Actions (the “scheduling order”) (Docket Number 5). The current deadline

28

is January 3, 2017, and the new deadline will be February 2, 2017. This is the first extension of time
STIPULATION & PROPOSED ORDER

1

(CIVIL NO.. 2:16-cv-02190-AC)

1
requested in the above-captioned matter. Defendant requests this additional time due to an inter-agency
2
delay in finalizing the certified administrative record for service. The parties further agree that the
3

scheduling order be modified accordingly.

4

Respectfully submitted,

5
Dated: December 29, 2016

LAW OFFICES OF LAWRENCE D. ROHLFING

6
By: /s/ Cyrus Safa*
CYRUS SAFA
(*As authorized by email on December 29, 2016)
Attorneys for Plaintiff

7
8
9
10

Dated: December 29, 2016

PHILLIP A. TALBERT
United States Attorney

11
By: /s/ Sharon Lahey
SHARON LAHEY
Special Assistant U. S. Attorney
Attorneys for Defendant

12
13
14

ORDER

15
16
17
18
19
20
21
22
23
24

Good cause appearing, pursuant to stipulation, IT IS SO ORDERED. Defendant shall respond to
the Complaint For Review of the Final Decision of the Social Security and serve a certified copy of the
transcript of the administrative record on or before February 2, 2017. Plaintiff shall serve new evidence
and/or a confidential settlement letter to Defendant on or before March 6, 2017. Defendant shall serve
her response to Plaintiff’s confidential settlement letter on or before April 5, 2017. In the event the
parties do not agree to remand, Plaintiff shall file her motion for summary judgment on or before May
10, 2017. Defendant shall file her response to Plaintiff’s motion for summary judgment on or before
June 9, 2017. Plaintiff shall file any reply on or before June 29, 2017.
DATED: January 4, 2017

25
26
27
28
STIPULATION & PROPOSED ORDER

2

(CIVIL NO.. 2:16-cv-02190-AC)