Opinion
Case No. 2:12-cv-02542-CMK
04-03-2013
RUTH D. COOKSON, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant.
BENJAMIN B.WAGNER United States Attorney GRACE M. KIM, SBN IL 6203390 Regional Chief Counsel, Region IX Social Security Administration CYNTHIA B. DE NARDI, CSBN 256770 Special Assistant United States Attorney Attorneys for Defendant KELSEY MACKENZIE BROWN Dellert Baird Law Offices, PLLC Attorney for Plaintiff
BENJAMIN B.WAGNER
United States Attorney
GRACE M. KIM, SBN IL 6203390
Regional Chief Counsel, Region IX
Social Security Administration
CYNTHIA B. DE NARDI, CSBN 256770
Special Assistant United States Attorney
Attorneys for Defendant
STIPULATION TO EXTEND BRIEFING
SCHEDULE AND [PROPOSED] ORDER
The parties hereby stipulate by counsel, with the Court's approval as indicated by issuance of the attached Order, that Defendant shall have a first extension of time of 30 days to respond to Plaintiff's motion for summary judgment. In addition to two motions for summary judgment in federal court due on April 10, 2013, the undersigned has deadlines in active employment discrimination cases before the Equal Employment Opportunity Commission (EEOC), including prehearing submissions due April 9, 2013 and a deposition in Los Angeles on April 10, 2013. Thus, counsel for the Commissioner requires additional time in order to respond to Plaintiff's arguments. The current date is April 10, 2013. The new due date will be May 10, 2013.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Respectfully submitted,
_______________
KELSEY MACKENZIE BROWN
(* by email authorization 4/2/13)
Dellert Baird Law Offices, PLLC
Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
By: _______________
CYNTHIA B. DE NARDI
Special Assistant United States Attorney
APPROVED AND SO ORDERED:
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CRAIG M. KELLISON
UNITED STATES MAGISTRATE JUDGE