Opinion
CASE NO. 2:12-CV-01084-EFB
02-19-2013
RONALD BRUCE THOMPSON, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant.
(As authorized via e-mail) ANN M. CERNEY Attorney for Plaintiff BENJAMIN B. WAGNER United States Attorney BRENDA M. PULLIN Special Assistant U.S. Attorney
BENJAMIN B. WAGNER
United States Attorney
GRACE M. KIM
Regional Chief Counsel, Region IX
BRENDA M. PULLIN
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8975
Facsimile: (415) 744-0134
E-Mail:Brenda.Pullin@ssa.gov
Attorneys for Defendant
STIPULATION AND PROPOSED ORDER
FOR SECOND EXTENSION OF TIME TO
FILE DEFENDANT'S CROSS-MOTION
The parties hereby stipulate through counsel, with the Court's approval as indicated by issuance of the attached Order, that Defendant shall have a second extension of time of 30 days to file his cross-motion for summary judgment.
The extension is being sought due to defense counsel's recent period of poor health; during the past month, defense counsel has been in the office on only six days. However, defense counsel continues to maintain her caseload and is diligently working through cases in the order of seniority. Given these constraints, defense counsel respectfully requests 30 additional days in which to file the Commissioner's cross-motion for summary judgment. Plaintiff's counsel does not object to the request. The new due date will be March 15, 2013.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Respectfully submitted,
______________
(As authorized via e-mail)
ANN M. CERNEY
Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
______________
BRENDA M. PULLIN
Special Assistant U.S. Attorney
IT IS SO ORDERED.
______________
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE