Mays v. Colvin

Filing 23

ORDER GRANTING 22 STIPULATION For A First Extension For Defendant to File Cross-Motion for Summary Judgment. Cross Motion and Separate Statement of Facts due by 2/17/2016. Signed by Judge Maria-Elena James on 12/10/2015. (cdnS, COURT STAFF) (Filed on 12/10/2015)

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MELINDA L. HAAG, CSBN 132612
United States Attorney
DEBORAH L. STACHEL, CSBN 230138
Acting 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
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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PHILLIP MAYS,
Plaintiff,
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CIVIL ACTION NO. 3:15-CV-02731-MEJ

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STIPULATION AND PROPOSED ORDER
FOR A FIRST EXTENSION FOR DEFENDANT
TO FILE CROSS-MOTION FOR SUMMARY
JUDGMENT

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)
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v.
)
)
CAROLYN W. COLVIN, Acting )
Commissioner of Social Security,
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Defendant.
)
______________________________)

IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that Defendant shall have a first extension of time of 65 days to file her cross-

motion for summary judgment and opposition to Plaintiff’s motion. The current due date is
21 December 14, 2015. The new due date will be February 17, 2016.
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This is the first continuance sought by Defendant. There is good cause for this request.
23 Defendant is seeking this extension due to Defendant’s counsel’s heavy workload in the last
24 month and continuing heavy workload in the next two months, including her regular district court
25 caseload, a hearing for an Equal Employment Opportunity Commission (EEOC) case on
26 December 4, 2015 with follow-up briefing; two other pending EEOC matters that require
27 discovery, including depositions in the next few weeks, and briefing; two Ninth Circuit briefs due
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in December 2015 and January 2016; and a Ninth Circuit appellate oral argument in early
Stip. & Prop. Order for Extension, 3:15-CV-02731-MEJ

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1 February 2016.
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Because of the factors described above, defense counsel is requesting additional time up

3 to February 17, 2016, to fully review the administrative record and research the issues presented
4 by Plaintiff’s memorandum in support of Plaintiff’s motion for summary judgment. Defendant
5 apologizes for any inconvenience caused by the delay in the filing of Defendant’s response to
6 Plaintiff’s motion for summary judgment.
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Respectfully submitted,
HOMELESS ACTION CENTER

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Dated: December 9, 2015

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/s/ Nancy McGee
(as authorized via e-mail on 12/9/2015)
Nancy McGee
Attorneys for Plaintiff

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MELINDA L. HAAG
United States Attorney

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Dated: December 9, 2015

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By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U.S. Attorney

Attorneys for Defendant
Defendant shall also file her Separate Statement of the Admin.
Record by 2/17/06. Plaintiff's Reply and Reply Statement of Facts
are due 3/2/06.
O

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22 PURSUANT TO STIPULATION, IT IS SO ORDERED.
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December 10, 2015
DATED:________________________

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HON. MARIA-ELENA JAMES
UNITED STATE MAGISTRATE JUDGE

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Stip. & Prop. Order for Extension, 3:15-CV-02731-MEJ

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