Despas v. Colvin

Filing 14

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

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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: (415) 977-8956 Facsimile: (415) 744-0134 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

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