Opinion
CASE NO. 2:11-CV-02417-EFB
04-06-2012
SEVERINO P. URSUA, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant.
BENJAMIN B. WAGNER United States Attorney DONNA CALVERT Acting Regional Chief Counsel, Region IX BRENDA M. PULLIN Special Assistant United States Attorney Social Security Administration Attorneys for Defendant
BENJAMIN B. WAGNER
United States Attorney
DONNA CALVERT
Acting Regional Chief Counsel, Region IX
BRENDA M. PULLIN
Special Assistant United States Attorney
Social Security Administration
Attorneys for Defendant
STIPULATION AND PROPOSED ORDER
FOR FIRST 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 first extension of time of 30 days to file his cross-motion for summary judgment.
The extension is being sought due to defendant's counsel's workload during the past month coupled with the Social Security Regional Counsel's office move at the end of March 2012—with all the associated preparations, organization meetings, and packing—which have taken more of counsel's time than projected. Defendant's counsel is responsible for moving her own office as well as helping to pack and move common office areas such as the fax and mail center, file areas, and unoccupied cubicles. In addition, after the move, unpacking and technological setup/troubleshooting of computer equipment has required additional unanticipated time and IT assistance before counsel's office can become fully functional.
Given these constraints, the Commissioner respectfully requests 30 additional days in which to complete the Commissioner's cross-motion for summary judgment. The new due date will be May 2, 2012.
The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. Respectfully submitted,
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(As authorized via e-mail)
ANN M. CERNEY Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
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BRENDA M. PULLIN
Special Assistant U.S. Attorney
IT IS SO ORDERED:
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EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE