Lloyd v. Astrue

Filing 20

STIPULATION AND ORDER EXTENDING TIME TO FILE CROSS-MOTION. Signed by Judge Edward M. Chen on 4/30/12. (bpf, COURT STAFF) (Filed on 5/2/2012)

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Case3:11-cv-04902-EMC Document19 Filed04/30/12 Page1 of 2 1 2 3 4 5 6 7 8 MELINDA L. HAAG, SBN CA 132612 United States Attorney DONNA CALVERT, SBN IL 6191786 Acting Regional Chief Counsel, Region IX Social Security Administration BRENDA M. PULLIN, SBN CO 35181 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, CA 94105 Telephone: 415-977-8975 Fax: 415-744-0134 E-mail: Brenda.Pullin@ssa.gov Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 CHARLIE LLOYD III, 13 14 15 16 17 ) ) Plaintiff, ) ) v. ) ) MICHAEL J. ASTRUE, ) Commissioner of Social Security ) ) Defendant. ) ____________________________________) CASE NO. 3:11-cv-4902-EMC STIPULATION AND PROPOSED ORDER FOR FIRST EXTENSION OF TIME TO FILE DEFENDANT’S CROSS-MOTION 18 19 20 The parties hereby stipulate through counsel, with the Court’s approval as indicated by issuance 21 of the attached Order, that Defendant shall have a first extension of time of 30 days to file his 22 cross-motion for summary judgment. 23 The extension is being sought due to defendant’s counsel’s workload during the past month 24 coupled with the Social Security Regional Counsel’s move to new office space at the end of March 25 2012—with all the associated preparations, organization, meetings, packing, and unpacking—which 26 have taken more of counsel’s time than projected. Defendant’s counsel was responsible for moving her 27 own office as well as helping to pack and move common office areas such as the fax and mail center, 28 file areas, and unoccupied cubicles. In addition, after the move, unpacking and technological Case3:11-cv-04902-EMC Document19 Filed04/30/12 Page2 of 2 1 setup/troubleshooting of computer equipment has required additional unanticipated time and IT 2 assistance before counsel’s office has become fully functional. 3 Given these constraints, along with counsel’s existing workload, the Commissioner respectfully 4 requests 30 additional days in which to complete the Commissioner’s cross-motion. The new due date 5 will be May 30, 2012. 6 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 7 8 Respectfully submitted, Dated: April 30, 2012 /s/ Robert C. Weems (As authorized via e-mail) ROBERT C. WEEMS Attorney for Plaintiff Dated: April 30, 2012 MELINDA L. HAAG United States Attorney 9 10 11 12 /s/ Brenda M. Pullin BRENDA M. PULLIN Special Assistant U.S. Attorney 13 14 15 16 17 IT IS SO ORDERED: S J ER H 24 25 26 27 28 2 R NIA FO RT 23 . Chen ward M udge Ed NO 22 LI 21 ____________________________________ RED EDWARD M. CHEN ORDE SO IT IS UNITED STATES DISTRICT JUDGE A 20 4/30/12 Dated: ________________ UNIT ED 19 RT U O 18 S DISTRICT TE C TA N F D IS T IC T O R C

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