UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION
August 8, 2012
PEREZ, SAMUEL GARCIA, XXX-XX-0023,
COMMISSIONER OF SOCIAL SECURITY,
The opinion of the court was delivered by: Carolyn K. Delaney United States Magistrate Judge
STIPULATION AND ORDER FOR A SECOND EXTENSION FOR DEFENDANT TO FILE NOTICE, MOTION, AND MEMORANDUM IN
SUPPORT OF CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO
PLAINTIFF'S MOTION FOR SUMMARY
IT IS HEREBY STIPULATED, by and between the undersigned attorneys, subject to the approval of the Court, that Defendant shall have a 30-day extension, or until September 7, 2012, in which to file his Notice, Motion, and Memorandum in Support of Cross-Motion for Summary Judgment and in Opposition to Plaintiff's Motion for Summary Judgment.
The undersigned counsel for the Defendant has exercised due diligence in managing her caseload and makes this request as a result of a heavy briefing schedule. This week the undersigned counsel for the Defendant has filed or will file dispositive briefs in the following matters: Prim v. Astrue (EDCA) 2:11-cv-03389-CKD, Gibson v. Astrue (EDCA) 2:11-cv-03330-KJN, and Taverniti v. Astrue (NDCA) 3:11-cv-06659-JW.
This request is not intended to cause intentional day. This is Defendant's second request for an extension of time in this matter.
Respectfully submitted, Dated: August 7, 2012 /s/ Ann M. Cerney (as authorized via telephone) ANN M. CERNEY Attorney for Plaintiff BENJAMIN WAGNER United States Attorney Dated: August 7, 2012 By /s/ Elizabeth Barry ELIZABETH BARRY Special Assistant U.S. Attorney Attorneys for Defendant
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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