Harris v. Colvin

Filing 19

STIPULATION AND ORDER FOR SECOND EXTENSION OF TIME [*AS MODIFIED BY THE COURT*]. Signed by Judge Yvonne Gonzalez Rogers on 2/22/16. (fs, COURT STAFF) (Filed on 2/22/2016)

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BRIAN STRETCH, CSBN 163973
Acting United States Attorney
DEBORAH LEE STACHEL, ISBN 230138
Acting Regional Chief Counsel, Region IX
Social Security Administration
JACOB M. MIKOW, CSBN 238045
Special Assistant United States Attorney
Social Security Administration
160 Spear St., Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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REGINA L. HARRIS,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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CIVIL NO. 4:15-CV-01312-YGR
STIPULATION AND PROPOSED
ORDER FOR SECOND EXTENSION
OF TIME FOR DEFENDANT TO FILE
CROSS-MOTION FOR SUMMARY
JUDGMENT AND OPPOSITION TO
PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT
*AS MODIFIED BY THE COURT*

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IT IS HEREBY STIPULATED, by and between the parties, that Defendant shall have an extension

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of time of 30 days to file a Cross-Motion for Summary Judgment and Opposition to Plaintiff’s Motion

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for Summary Judgment. This is Defendant’s second request for an extension of time to respond to

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Plaintiff’s motion. Assistant Regional Counsel In Seon Jeong was assigned to this case and has

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diligently attempted to complete Defendant’s responsive brief in a timely matter. However, the
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undersigned counsel for Defendant seeks this extension due to the press of workload including a high

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Stip. & Prop. Order for Extension, 4:15-CV-01312-YGR

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volume of other disability matters. Counsel apologizes to the Court for any inconvenience caused by

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this delay.

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The new due date for Defendant’s Cross-Motion and Opposition will be March 19, 2016. The
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parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: February 17, 2016

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By: /s/ Donald H. Medearis
DONALD H. MEDEARIS
(as authorized via-email on February 17, 2016)
MELINDA L. HAAG BRIAN STRETCH
United States Attorney

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Dated: February 17, 2016

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By: /s/ Jacob M. Mikow
JACOB M. MIKOW
Special Assistant United States Attorney
Attorneys for Defendant

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Of Counsel:
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IN SEON JEONG
Assistant Regional Counsel

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. However, as this is the second request for
workload related issues, no further extensions will be granted absent extraordinary circumstances.

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Counsel is instructed to amend his template to reflect the current United States Attorney.

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February 22, 2016
DATED:________________________
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HON. YVONNE GONZALEZ ROGERS
UNITED STATE DISTRICT COURT JUDGE

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Stip. & Prop. Order for Extension, 4:15-CV-01312-YGR
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