Opinion
Case No.: 2:16-cv-00941-CMK
05-25-2017
FRANCISCO ROBERTO VASQUEZ, Plaintiff, v. CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant.
PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CAROLYN B. CHEN, CSBN 256628 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Carolyn.Chen@ssa.gov Attorneys for Defendant
PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8956
Facsimile: (415) 744-0134
E-Mail: Carolyn.Chen@ssa.gov
Attorneys for Defendant MOTION FOR AN EXTENSION OF TIME OF 21 DAYS FOR DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
Defendant, through her counsel of record, moves for an extension of time of an additional 21 days to respond to Plaintiff's motion for summary judgment. This is the second continuance sought by Defendant. The current due date is May 26, 2017. The new due date will be June 16, 2017.
There is good cause for this request. Since the filing of Plaintiff's motion for summary judgment, in the last few days, Defendant's counsel has come down with flu-like symptoms which will keep her from filing Defendant's response to Plaintiff's Motion for Summary Judgment timely. Furthermore, in the next few weeks, Defendant's counsel has pre-approved leave and a continuing full workload of about seven pending District Court briefs and one district court hearing to address. Therefore, Defendant is respectfully requesting additional time up to and including June 16, 2017, to fully review the record and research the issues presented by Plaintiff's motion for summary judgment, as Defendant's counsel recovers from her sickness and addresses her workload. This request is made in good faith with no intention to unduly delay the proceedings.
Defendant moves that the Court's Scheduling Order shall be modified accordingly.
On May 23, 2017, Defendant reached out to Plaintiff through his counsel Steven Rosales of Law Offices of Lawrence D. Rohlfing, and Plaintiff through his counsel confirmed on May 24, 2017 that he had no objection to the motion. Date: May 24, 2017
Respectfully submitted,
PHILLIP A. TALBERT
United States Attorney
By s/ Carolyn B . Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED: Dated: May 25, 2017
/s/_________
CRAIG M. KELLISON
UNITED STATES MAGISTRATE JUDGE