Filed: Dec. 12, 2017
Latest Update: Dec. 12, 2017
Summary: STIPULATION AND PROPOSED ORDER MODIFYING SCHEDULING ORDER ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED by and between the parties, subject to the Court's approval, that the scheduling order in this action be further modified to extend the parties filing deadlines by roughly 25 days. Modification is necessary, appropriate and in the interests of judicial economy because after the exchange of letter briefs, plaintiff's counsel became aware of additional medical records whic
Summary: STIPULATION AND PROPOSED ORDER MODIFYING SCHEDULING ORDER ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED by and between the parties, subject to the Court's approval, that the scheduling order in this action be further modified to extend the parties filing deadlines by roughly 25 days. Modification is necessary, appropriate and in the interests of judicial economy because after the exchange of letter briefs, plaintiff's counsel became aware of additional medical records which..
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STIPULATION AND PROPOSED ORDER MODIFYING SCHEDULING ORDER
ERICA P. GROSJEAN, Magistrate Judge.
IT IS HEREBY STIPULATED by and between the parties, subject to the Court's approval, that the scheduling order in this action be further modified to extend the parties filing deadlines by roughly 25 days.
Modification is necessary, appropriate and in the interests of judicial economy because after the exchange of letter briefs, plaintiff's counsel became aware of additional medical records which he believes constitutes new and material evidence warranting remand under 42 U.S.C. § 405(g), sentence six; such records have been provided for review by the Commissioner of Social Security, whose review was ongoing until recently, but has not resulted in the resolution of this action. To provide adequate time for plaintiff to complete her motion for summary judgment and meet the professional standards of the Court, plaintiff's counsel requires an extension of existing deadlines by 25 days in light of interruptions associated with upcoming holidays and unanticipated demands in his criminal calendar and other matters now pending. The parties believe and agree that a roughly 25 day extension of their respective merits filing deadlines is appropriate and is not prejudicial to either party.
Accordingly, the parties agree to and request modification of the existing scheduling order and outstanding deadlines, as follows:
January 5, 2018: Plaintiff to file and serve motion for summary judgment.
February 5, 2018: Defendant to file and serve cross-motion for summary judgment.
February 19, 2018: Plaintiff to file and serve response to cross-motion.
SO STIPULATED AND AGREED:
ORDER
Pursuant to the parties' stipulation, the existing scheduling order and outstanding deadlines are CONTINUED as follows:
January 5, 2018: Plaintiff to file and serve motion for summary judgment.
February 5, 2018: Defendant to file and serve cross-motion for summary judgment.
February 19, 2018: Plaintiff to file and serve response to cross-motion.
No further extensions of time will granted in this case.
IT IS SO ORDERED.
