Opinion
CIVIL NO.: 3:12-cv-05315-EMC
03-11-2013
GEBREMEDHIN HADERA, Plaintiff, v. CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant.
MELINDA L. HAAG, CSBN 132612 United States Attorney GRACE M. KIM, SBN IL 6203390 Regional Chief Counsel, Region IX Social Security Administration LYNN M. HARADA, CSBN 267616 Special Assistant United States Attorney Attorneys for Defendant STEVEN M. CHABRE Attorney for Plaintiff
MELINDA L. HAAG, CSBN 132612
United States Attorney
GRACE M. KIM, SBN IL 6203390
Regional Chief Counsel, Region IX
Social Security Administration
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
Attorneys for Defendant
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME
IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that the time for responding to Plaintiff's Motion for Summary Judgment be extended from March 19, 2013, to April 19, 2013. This is Defendant's first request for an extension of time to respond to Plaintiff's motion. Defendant needs the additional time to further review the file and prepare a response in this matter due to a heavy workload and pre-approved leave, despite due diligence.
Counsel for Defendant sincerely apologizes to the Court and to Plaintiff for any inconvenience caused by this delay.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Respectfully submitted,
_______________
(As authorized via e-mail on 3/7/13)
STEVEN M. CHABRE
Attorney for Plaintiff
MELINDA L. HAAG
United States Attorney
GRACE M. KIM
Regional Chief Counsel, Region IX
Social Security Administration
By: _______________
LYNN M. HARADA
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
_______________
THE HONORABLE EDWARD M. CHEN
United States District Judge