Castaneda v. Colvin

Filing 24

ORDER GRANTING 23 Motion for Extension of Time to File Response to 22 MOTION for Summary Judgment. Responses due by 9/15/2015. Signed by Judge Jeffrey S. White on August 28, 2015. (jswlc3, COURT STAFF) (Filed on 8/28/2015)

Case4:14-cv-05515-JSW Document23 Filed08/28/15 Page1 of 2

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MELINDA L. HAAG, CSBN 132612
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
CHANTAL R. JENKINS, SBN PA 307531
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ROSANA CASTANEDA
Plaintiff,
vs.

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CAROLYN W. COLVIN,
Acting Commissioner of
Social Security,

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Defendant.

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CIVIL NO. 4:14-cv-05515-JSW
STIPULATION & PROPOSED ORDER
FOR A 14-DAY EXTENSION FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of

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record, that Defendant shall have an extension of time of 14 days to respond to Plaintiff’s motion for

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summary judgment. The current due date is September 1, 2015. The new due date will be September

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15, 2015.

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Defendant respectfully requests this additional time because Defendant’s counsel is managing a

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heavy caseload. Defendant’s counsel is currently responsible for managing and briefing forty-three

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other matters pending before the District Courts. Counsel is also in the process of completing a ninth

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circuit appellate brief, which must be reviewed by the Office of General Counsel and the United States

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Stipulation and Proposed Order for an Extension of Time; 4:14-cv-05515-JSW

Case4:14-cv-05515-JSW Document23 Filed08/28/15 Page2 of 2

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Department of Justice (DOJ). In addition, counsel is representing the agency in a federal employment

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discrimination case and is in the process of gathering and serving documents for discovery.

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This request is made in good faith with no intention to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,
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Dated: August 28, 2015

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/s/_Barbara Mann by Chantal R. Jenkins*__
As authorized via email on August 28, 2015
Barbara Mann
Attorney for Plaintiff

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Respectfully submitted,

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MELINDA L. HAAG
United States Attorney

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Dated: August 28, 2015

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/s/ Chantal R. Jenkins
Chantal R. Jenkins
Special Assistant United States Attorney

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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August 28, 2015
DATED:________________________

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HON. JEFFREY S. WHITE
UNITED STATE DISTRICT JUDGE

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Stipulation and Proposed Order for an Extension of Time; 4:14-cv-05515-JSW