Opinion
CASE NO.: 2:12-CV-00851-DAD
09-12-2012
DALENE INGRAHAM, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant,
LAW OFFICE OF ELIZABETH GADE, INC. Stephen A. Valizan Attorney for Plaintiff BENJAMIN B. WAGNER United States Attorney DONNA L. CALVERT Acting Regional Chief Counsel, Region IX Social Security Administration DANIEL P. TALBERT Special Assistant U.S. Attorney Attorneys for Defendant
ELIZABETH L. GADE (SBN: 161495)
STEPHEN A. VALIZAN (SBN: 260861)
LAW OFFICE OF ELIZABETH GADE, INC.
Attorneys for Plaintiff
STIPULATION AND ORDER FOR FIRST
EXTENSION OF TIME TO FILE
PLAINTIFF'S MOTION FOR SUMMARY
JUDGMENT
The parties hereby stipulate by counsel, with the Court's approval as indicated by issuance of the attached Order, that plaintiff shall have a first extension of time of 30 days to file her motion for summary judgment.
This is the first request for an extension of time for plaintiff to file her motion for summary judgment.
Counsel for plaintiff respectfully requests an extension of time due to his workload, which includes multiple district court matters, administrative hearings and other duties related to the representation of clients before the Social Security Administration.
The current due date for plaintiff's motion for summary judgment is September 27, 2012. The new due date will be October 27, 2012, which is a Saturday. As such, plaintiff's brief will be due Monday, October 29, 2012.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Respectfully submitted,
LAW OFFICE OF ELIZABETH GADE, INC.
Stephen A. Valizan
Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration
Daniel P. Talbert (Authorized via Email)
DANIEL P. TALBERT
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED.
____________________
DALE A. DROZD
UNITED STATES MAGISTRATE JUDGE