Colburn v. Colvin

Filing 14

STIPULATION AND ORDER FOR AN EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION FORSUMMARY JUDGMENT re 13 STIPULATION WITH PROPOSED ORDER filed by Robert Colburn. Signed by Judge Jon S. Tigar on June 19, 2015. (wsn, COURT STAFF) (Filed on 6/19/2015)

1
2
3
4
5
6

DONALD H. MEDEARIS, SBN 206849
BAY AREA LEGAL AID
1035 Market Street, 6th Floor
San Francisco, CA 94103
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff,
ROBERT COLBURN

7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

SAN FRANCISCO DIVISION

11 ROBERT COLBURN,
12
13

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

Plaintiff,
vs.

14 CAROLYN W. COLVIN, Acting
15 Commissioner of the Social Security
Administration,
16
Defendant.
17
18
19

Case No. 3:15-CV-00586-JST
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME FOR
PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by and between parties, through their representative
counsel of record, that Plaintiff shall have a first extension of time of 90 days to file his

20
21
22

Motion For Summary Judgement in response to Defendant's Answer . The new date for filing
Plaintiff's Motion for Summary Judgement will be September 21, 2015.

23

This extension is necessary because Donald H. Medearis substituted in as Plaintiff's

24

attorney on June 16, 2015, was not the Plaintiff's attorney in the administrative proceeding,

25

therefore needs more time to familiarize himself with the law and facts of the case to

26
27

properly prepare the Motion For Summary Judgment, and already has a substantial caseload.

28
STIPULATION TO EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 3:15-CV-00586-JST

1

further stipulate that the Court's Scheduling Order shall be modified accordingly.

3
Dated: June 17, 2015

/s/Donald H. Medearis
DONALD H. MEDEARIS
BAY AREA LEGAL AID

Dated: June 17, 2015

MELINDA L. HAAG
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration

5
6

8
9
10
By:

11

/s/Richard M. Rodriguez
(* as authorized by e-mail on June 17, 2015)
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
Attorneys for Defendant

12
13
14

16

APPROVED AND SO ORDERED

17

June 19, 2015
Dated: ____________

18

n S.
J u d ge J o

ER

Ti ga r

H

21

THE HONORABLE JON S. TIGAR

RT

20

ERED
O ORD
By:_____________________________
IT IS S

NO

19

UNIT
ED

S

ORDER:

RT
U
O

15

S DISTRICT
TE
C
TA

22

R NIA

7

FO

4

Respectfully submitted,

LI

2

Plaintiff's Attorney apologizes to the Court and Opposing Counsel for the delay. The parties

A

1

N

D IS T IC T
R

OF

C

23
24
25
26
27
28
STIPULATION TO EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 3:15-CV-00586-JST

2