Thornton v. Commissioner of Social Security

Filing 23

ORDER on Joint Stipulation for Extension of Time for Defendant to Respond to Plaintiff's Motion for Summary Judgment, signed by Magistrate Judge Gary S. Austin on 6/16/17: Response deadline EXTENDED from June 19, 2017 to July 19, 2017. (Hellings, J)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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JENYNE THORNTON,

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Plaintiff,

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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:16-CV-00816-GSA
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for thirty

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days from June 19, 2017 to July 19, 2017. This is Defendant’s first request for extension.

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Good cause exists to grant Defendant’s request for extension. Additional time is required as

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counsel for Defendant was out of the office on sick leave last week and has been suffering from

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ongoing debilitating migraines. As a result, Counsel was not able to adequately research and

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review the transcript in time to adequately respond to Plaintiff’s Motion for Summary Judgment.

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In addition, good cause exists as due to current workload demands and shortened staff, counsel

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has a total of four dispositive motions to respond to this week, as well as two + dispositive
JS for Extension of Time, Case No. 1:16-CV-00816-GSA

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motions per week until mid-July. Defendant makes this request in good faith with no intention

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to unduly delay the proceedings. The parties further stipulate that the Court’s Scheduling Order

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shall be modified accordingly.

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Respectfully submitted,

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Dated: June 12, 2017

/s/ *Melissa Newel
(*as authorized by email on June 12, 2017)
MELISSA NEWEL
Attorney for Plaintiff

Dated: June 12, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER
APPROVED AND SO ORDERED.

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IT IS SO ORDERED.
Dated:

June 16, 2017

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time, Case No. 1:16-CV-00816-GSA

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