Opinion
CIVIL NO. 2:12-cv-00033-KJN
08-10-2012
SHIRLEY RENE MARTIN, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant.
Respectfully submitted, Ann M. Cerney Attorney for Plaintiff BENJAMIN B. WAGNER United States Attorney DONNA L. CALVERT Acting Regional Chief Counsel, Region IX Social Security Administration DAVID LERCH Special Assistant U.S. Attorney Attorneys for Defendant
BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT, IL SBN 6191786
Acting Regional Chief Counsel, Region IX
Social Security Administration
DAVID W. LERCH, CA SBN 229411
Special Assistant United States Attorney
Attorneys for Defendant
STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO FILE
DEFENDANT'S CROSS-MOTION FOR
SUMMARY JUDGMENT
The parties hereby stipulate by counsel, with the Court's approval as indicated by issuance of the attached Order, that Defendant shall have a first extension of time of 30 days to respond to Plaintiff's motion for summary judgment.
The Court has previously granted a request for an extension of time for Plaintiff to file a motion for summary judgment. This is the first request for an extension of time for Defendant to file his cross-motion for summary judgment.
Counsel for Defendant respectfully requests an extension of time due to his workload. In particular, counsel is currently responsible for approximately 50 district court cases at various stages of litigation. Counsel also is responsible for certain requests for legal advice and guidance from other SSA components, and was required to devote an unexpected amount of time in the past week to such a matter.
The current due date for Defendant's cross-motion for summary judgment is August 10, 2012. The new due date will be September 10, 2012.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.
Respectfully submitted,
_________________
Ann M. Cerney
Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration
_________________
DAVID LERCH
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED.
_________________
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE