Mullen v. Colvin

Filing 16

STIPULATION AND ORDER TO EXTEND re 15 STIPULATION WITH PROPOSED ORDER for Extension of Time to File Defendant's Cross-Motion for Summary Judgment and Opposition filed by Kevin Mullen, Carolyn W. Colvin, Set/Reset Deadlines as to 15 STIPULATION WITH PROPOSED ORDER for Extension of Time to File Defendant's Cross-Motion for Summary Judgment and Opposition, 11 MOTION for Summary Judgment . Responses due by 10/17/2016. Replies due by 10/24/2016. Signed by Magistrate Judge Kandis A. Westmore on 9/21/16. (sisS, COURT STAFF) (Filed on 9/21/2016)

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1 2 3 4 5 6 7 8 9 10 BRIAN STRETCH, CSBN 163973 United States Attorney DEBORAH LEE STACHEL, CSBN 230138 Regional Chief Counsel, Region IX Social Security Administration TIMOTHY R. BOLIN, CSBN 259511 Special Assistant United States Attorney Social Security Administration Office of the General Counsel 160 Spear St Ste 800 San Francisco, CA 94105 Telephone: (415) 977-8982 Facsimile: (415) 744-0134 Email: Timothy.Bolin@ssa.gov Attorneys for Defendant UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 13 14 KEVIN MULLEN, Plaintiff, 15 vs. 16 17 CAROLYN W. COLVIN, Acting Commissioner of Social Security, 18 Defendant. 19 ) Case No: 4:16-cv-00848-KAW ) ) JOINT STIPULATION AND PROPOSED ) ORDER FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) 20 IT IS HEREBY STIPULATED, by and between the parties, through their respective 21 22 counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary 23 Judgment be extended for 30 days from September 15, 2016 to October 17, 2016. This is 24 Defendant’s second request for an extension of time to respond to Plaintiff’s motion. Defendant 25 respectfully requests this extension to further consult with client to obtain relevant information 26 critical to Defendant’s defense. 27 /// 28 /// Joint Stip. & Prop. Order for Ext.; 4:16-cv-00848-KAW 1 1 The parties stipulate in good faith, with no intent to prolong proceedings unduly. 2 The parties further stipulate that all subsequent deadlines set forth in the Court’s 3 Procedural Order for Social Security Review Actions shall be extended accordingly. 4 Respectfully submitted, 5 6 Dated: September 13, 2016 /s/ Michael Wolchansky* (* As authorized via email on September 13, 2016) MICHAEL WOLCHANSKY 7 8 Attorney for Plaintiff 9 10 Dated: September 13, 2016 BRIAN STRETCH United States Attorney 11 By: 13 /s/ Timothy R. Bolin TIMOTHY R. BOLIN Special Assistant United States Attorney 14 Attorneys for Defendant 12 15 16 17 Of Counsel to Defendant: BEATRICE NA Assistant Regional Counsel 18 19 ORDER 20 21 APPROVED AND SO ORDERED: 22 23 Dated: _____________ 9/21/16 24 __________________________________ THE HONORABLE KANDIS A. WESTMORE United States Magistrate Judge 25 26 27 28 Joint Stip. & Prop. Order for Ext.; 4:16-cv-00848-KAW 2

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