Sartiaguda v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER FOR AN EXTENSION OF TIME OF 45 DAYS FOR DEFENDANT'S RESPONSE TO MOTION FOR SUMMARY JUDGMENT signed by Magistrate Judge Craig M. Kellison on 7/24/18. The new due date will be 9/4/18. (Mena-Sanchez, L)

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MCGREGOR W. SCOTT
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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ALVIN SARTIAGUDA,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-02280-CMK
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 45 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 45 additional days to

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respond to Plaintiff’s motion for summary judgment. The current due date was July 19, 2018.

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The new due date will be September 4, 2018 (since September 2, 2018 falls on the weekend,

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followed by the federal holiday on September 3, 2018).

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This is Defendant’s second request for an extension of time in this case. There is good

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cause for this request. Since the Court’s granting of the Defendant’s request for an extension of

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time, Defendant’s counsel has been addressing a full workload of district court matters and other

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matters that could not be assigned to another attorney. In addition, the parties have begun

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discussion of a possible voluntary remand settlement, and Defendant is requesting additional

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time to review the case. Lastly, additional time is necessary given that Defendant’s counsel will

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be on pre-approved leave for multiple weeks including in August.

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Thus, Defendant is respectfully requesting additional time up to and including September

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4, 2018, to respond to Plaintiff’s motion for summary judgment in this case, should the case not

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go forward with a voluntary remand. Defendant apologizes for the tardy request. This request is

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made in good faith with no intention to unduly delay the proceedings.

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Respectfully submitted,
Date: July 20, 2018

LAW OFFICES OF LAWRENCE D. ROHLFING

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s/ Lawrence D. Rohlfing by C.Chen*
(As authorized by email on 7/20/2018)
LAWRENCE D. ROHLFING
Attorneys for Plaintiff

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Date: July 20, 2018

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MCGREGOR W. SCOTT
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: July 24, 2018

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