Opinion
Case No. 2:12-CV-02243-AC
04-25-2013
JASON HUTNICK, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant.
BESS M. BREWER Attorney for Plaintiff BENJAMIN B. WAGNER United States Attorney CAROLYN B. CHEN Special Assistant U. S. Attorney Attorneys for Defendant
BENJAMIN B. WAGNER
United States Attorney
GRACE M. KIM
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8956
Facsimile: (415) 744-0134
E-Mail: Carolyn.Chen@ssa.gov
Attorneys for Defendant
STIPULATION AND PROPOSED ORDER FOR
A FIRST EXTENSION OF 45 DAYS FOR
DEFENDANT TO RESPOND TO PLAINTIFF'S
MOTION FOR SUMMARY JUDGMENT
IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have a first extension of time of 45 days to respond to Plaintiff's Motion for Summary Judgment. This is the first continuance sought by Defendant. Defendant's counsel requests additional time due to a recent and unanticipated reassignment of work assigned to Defendant's counsel that could not be reassigned to another attorney, thus causing an unanticipated increase of press of business. In addition, Defendant's counsel has 9 district court briefs due in the next month. Thus, Defendant's counsel would appreciate the additional time to fully research the issues presented by Plaintiff's 47-page memorandum of points and authorities. The current due date is April 26, 2013. The new due date will be June 10, 2013.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Defendant's counsel apologizes to the Court and to Plaintiff for any inconveniences caused by this extension.
Respectfully submitted,
___________
(As authorized by email on 4/24/2013)
BESS M. BREWER
Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
By ___________
CAROLYN B. CHEN
Special Assistant U. S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED:
___________
ALLISON CLAIRE
UNITED STATES MAGISTRATE JUDGE