Iris M. Valencia v. Commissioner of Social Security

Filing 19

STIPULATION AND ORDER FOR A FIRST EXTENSION OF TIME FOR DEFENDANT TO FILE HER MOTION FOR SUMMARY JUDGMENT, AS MODIFIED 18 : The new due date for Defendant's Motion for Summary Judgment will be Monday, February 13, 2017. Plaintiff shall have until February 27, 2017, to respond to Defendant's Motion. Signed by Judge Elizabeth D. Laporte on 1/25/2017. (afmS, COURT STAFF) (Filed on 1/25/2017)

1
2
3
4
5
6
7
8
9

MELINDA HAAG
United States Attorney
DEBORAH LEE STACHEL
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: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

10

UNITED STATES DISTRICT COURT

11

NORTHERN DISTRICT OF CALIFORNIA

12
SAN FRANCISCO DIVISION
13
14

IRIS M. VALENCIA,

15

Plaintiff,

16

v.

17
18
19
20

CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

)
)
)
)
)
)
)
)
)
)
)

Civil No. 3:16-cv-03004-EDL
STIPULATION AND PROPOSED ORDER
FOR A FIRST EXTENSION OF TIME
FOR DEFENDANT TO FILE HER
MOTION FOR SUMMARY JUDGMENT
AS MODIFIED

21
22

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, and

23

with the approval of the Court, that Defendant shall have a first extension of time of 30 days to

24

file her motion for summary judgment. Defendant respectfully requests this additional time

25

because of the heavy accumulated workload following two weeks of leave over the holidays, and

26

because the undersigned has an upcoming oral argument in the Ninth Circuit in early February.

27
28
1

1
2

The new due date for Defendant’s motion for summary judgment will be Monday,
February 13, 2017.

Plaintiff shall have until February 27, 2017 to respond to Defendant's Motion.

3
4
Respectfully submitted,

5
6

Date: January 25, 2017

7

LAW OFFICES OF LAWRENCE D. ROHLFING
By:

8
9

/s/ Jeffrey Chen for Cyrus Safa*
CYRUS SAFA
* By email authorization on Jan. 25, 2017
Attorney for Plaintiff

10
11

Date: January 25, 2017

MELINDA HAAG
United States Attorney

12
By:
13
14

/s/ Jeffrey Chen
JEFFREY CHEN
Special Assistant United States Attorney
Attorneys for Defendant

15
16
17
18
19

ORDER

20
21

APPROVED AND SO ORDERED:

22

DATED:

23

January 25, 2017

HON. ELIZABETH D. LAPORTE
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28
2