Walsh v. Colvin

Northern District of California, cand-4:2015-cv-02737

STIPULATION AND ORDER re {{33}} STIPULATION WITH PROPOSED ORDER for a Thirty-Day Extension for Defendant to File her Cross-Motion for Summary Judgment filed by Michael P Walsh, Carolyn W. Colvin. Signed by Magistrate Judge Kandis A. Westmore on 12/16/16.

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1 BRIAN J. STRETCH, CSBN 163973 United States Attorney 2 DEBORAH LEE STACHEL, CSBN 230138 Regional Chief Counsel 3 DANIEL P. TALBERT, SNB OH 0084088 Special Assistant United States Attorney 4 Social Security Administration 160 Spear Street, Suite 800 5 San Francisco, CA 94105 Telephone: (415) 977-8995 6 Facsimile: (415) 977-8873 Attorneys for Defendant 7 8 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 MICHAEL P. WALSH, No. 4:15-cv-02737-KAW 13 Plaintiff, 14 STIPULATION AND PROPOSED ORDER v. FOR A THIRTY-DAY EXTENSION FOR 15 DEFENDANT TO FILE HER CROSS- CAROLYN W. COLVIN, 16 Acting Commissioner of Social Security, MOTION FOR SUMMARY JUDGMENT 17 Defendant. 18 19 The parties stipulate that, subject to the approval of the Court, that Defendant shall be 20 granted a thirty-day extension from the current December 16, 2016 deadline to file a cross-motion 21 for summary judgment. This is Defendant's second request for an extension. There is good 22 cause for this extension because the attorney assigned to brief the case is out of the office on 23 parental leave. The previously assigned attorney had planned this leave, but had to take leave 24 sooner than he had anticipated. The office representing the Commissioner in this case must 25 reassign this matter to another attorney, who will require additional time to become familiar with 26 the case, properly respond to Plaintiff's arguments, and otherwise provide proper representation 27 to the Commissioner. The undersigned attorney is handling this matter for purposes of this 28 extension only. Therefore, the parties jointly request an extension up to and including January 1 1 16, 2017. 2 Respectfully submitted December 14, 2016. 3 4 DATED: December 14, 2016 /s/ Steven G. Rosales STEVEN G. ROSALES 5 (as authorized via email) Attorney for Plaintiff 6 BRIAN J. STRETCH 7 United States Attorney 8 DATED: December 14, 2016 By s/ Daniel P. Talbert DANIEL P. TALBERT 9 Special Assistant United States Attorney 10 Attorneys for Defendant 11 12 ORDER 13 14 Pursuant to stipulation, it is so ordered. 15 DATE: 12/16/16 _______________________________ HON. KANDIS A. WESTMORE 16 UNITED STATES MAGISTRATE JUDGE 17 18 19 20 21 22 23 24 25 26 27 28 2