Sullivan v. Commissioner of Social Security

Filing 27

ORDER GRANTING: 26 STIPULATION WITH PROPOSED ORDER Extending Time to File Defendant's MSJ filed by Commissioner of Social Security. Cross Motions due by 4/15/2016. Signed by Judge Maria-Elena James on 4/8/2016. (cdnS, COURT STAFF) (Filed on 4/8/2016)

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1 2 3 4 5 6 7 8 9 MELINDA HAAG United States Attorney DEBORAH LEE STACHEL Acting Regional Chief Counsel, Region IX Social Security Administration JEFFREY CHEN, CSBN 260516 Special Assistant United States Attorney Social Security Administration 160 Spear Street, Suite 800 San Francisco, CA 94105 Telephone: (415) 977-8939 Facsimile: (415) 744-0134 Email: Jeffrey.Chen@ssa.gov Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 TERREA LYNN SULLIVAN, 15 Plaintiff, 16 v. 17 18 19 CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant. 20 ) ) ) ) ) ) ) ) ) ) ) No. 3:15-cv-03555-MEJ STIPULATION AND PROPOSED ORDER FOR A THIRD EXTENSION OF TIME FOR DEFENDANT TO FILE HER MOTION FOR SUMMARY JUDGMENT 21 IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and 22 with the approval of the Court, that Defendant shall have a third extension of time of 7 days to 23 file her motion for summary judgment. Defendant respectfully request this additional time 24 because after reviewing the evidence of record and Plaintiff’s contentions, the undersigned 25 believes that this case warrants consideration for voluntary remand in lieu of further litigation. 26 The additional seven days will the agency to complete its review and makes its determination. 27 28 Stipulation to Extend Def.’s MSJ 1 1 2 The new due date for Defendant’s motion for summary judgment will be Friday, April 15, 2016. 3 Respectfully submitted, 4 5 Date: April 8, 2016 6 LAW OFFICES OF LAWRENCE D. ROHLFING By: 7 8 /s/ Young Chul Cho* YOUNG CHUL CHO * By email authorization on April 8, 2016 Attorney for Plaintiff 9 10 Date: April 8, 2016 MELINDA HAAG United States Attorney 11 By: 12 13 /s/ Jeffrey Chen JEFFREY CHEN Special Assistant United States Attorney Attorneys for Defendant 14 15 16 ORDER 17 18 19 APPROVED AND SO ORDERED: 20 DATED: April 8, 2016 HONORABLE MARIA-ELENA JAMES UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26 27 28 Stipulation to Extend Def.’s MSJ 2

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