Opinion
Case No.: 2:13-cv-00319-DAD
03-25-2013
BENJAMIN B. WAGNER United States Attorney GRACE M. KIM Regional Chief Counsel, Region IX Social Security Administration DANIEL TALBERT Special Assistant United States Attorney Attorneys for Defendant
BENJAMIN B. WAGNER
United States Attorney
GRACE M. KIM
Regional Chief Counsel, Region IX
Social Security Administration
DANIEL TALBERT
Special Assistant United States Attorney
Attorneys for Defendant
STIPULATION AND ORDER FOR AN
EXTENSION OF 30 DAYS FOR
PLAINTIFF TO FILE HER MOTION FOR
SUMMARY JUDGMENT
The parties hereby stipulate through their undersigned counsel, subject to the approval of the Court, that Plaintiff shall have an extension up to and including May 6, 2013, to file her motion for summary judgment. This extension is necessary because the parties continue to conduct settlement discussions pursuant to the initial scheduling order in this case. The scheduling order directed Defendant to respond to Plaintiff's informal settlement letter by March 22, 2013, but because of recent inclement weather in the Washington, D.C., area, counsel for
Defendant's client contact has requested additional time to review settlement requests. Therefore, the parties require additional time to address the possibility of settlement fully.
Based on the initial scheduling order, Plaintiff's motion for summary judgment is due April 22, 2013. The parties request a 14-day extension for Plaintiff's deadline, up to and including May 6, 2013.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Respectfully submitted,
CYRUS SAFA
By: __________
CYRUS SAFA
(As authorized by email on March 22, 2013)
Attorneys for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
By: __________
DANIEL TALBERT
Special Assistant U. S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED.
______________________
DALE A. DROZD
UNITED STATES MAGISTRATE JUDGE