Despas v. Colvin

Filing 14

Order by Magistrate Judge Donna M. Ryu granting 13 Stipulation.(dmrlc2, COURT STAFF) (Filed on 7/16/2014)

Case4:14-cv-00681-DMR Document13 Filed07/15/14 Page1 of 2

1
2
3
4
5
6
7
8
9
10

MELINDA L. HAAG, CSBN 132612
United States Attorney
DONNA L. CALVERT, SBN IL 6191786
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

11
12

JOEL DESPAS,
Plaintiff,
13

CIVIL ACTION NO. 4:14-CV-00681-DMR

14

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

15
16
17
18
19
20

)
)
)
v.
)
)
CAROLYN W. COLVIN, Acting )
Commissioner of Social Security,
)
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 45 days to file her cross-

motion for summary judgment and opposition to Plaintiff’s motion. The current due date is July
21 22, 2014. The new due date will be September 5, 2014.
22
This is the first continuance sought by Defendant. There is good cause for this request.
23 Defendant’s counsel has a heavy workload around the time of the due date of Defendant’s brief,
24 including an Equal Employment Opportunity Commission (EEOC) hearing from July 23-25, for
25 which she will be on travel and out of town and has to conduct preparation of seven witnesses.
26 Upon defense counsel’s return after the hearing, she will continue to have a heavy workload,
27 including two ninth circuit matters, another EEOC matter, at least six other pending district court
28 cases, and a multi-day training in August. Defendant’s counsel requests additional time to fully
Stip. & Prop. Order for Extension, 4:14-CV-00681-DMR

1

Case4:14-cv-00681-DMR Document13 Filed07/15/14 Page2 of 2

1 review the administrative record and fully research the issues presented by Plaintiff in this case.
2

Counsel for Defendant apologizes to the Court and to Plaintiff for any inconvenience

3 caused by the delay in the filing of Defendant’s response to Plaintiff’s motion for summary
4 judgment.
5

Respectfully submitted,

6

LAW OFFICES OF HARRY J. BINDER AND
CHARLES E. BINDER, PC

7
8

Dated: July 15, 2014

9
10

/s/ Omar O. Ortega
(as authorized via e-mail on 7/15/2014)
Omar O. Ortega
Attorney for Plaintiff
MELINDA L. HAAG
United States Attorney

11
12

14

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

15

Attorneys for Defendant

13

Dated: July 15, 2014

16
17
ORDER

18
19

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20
July 16, 2014
21 DATED:________________________
22

23

_________________________________
HON. DONNA M. RYU
UNITED STATE MAGISTRATE JUDGE

24
25
26
27
28
Stip. & Prop. Order for Extension, 4:14-CV-00681-DMR

2