Thomas v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 5/19/2017 for receipt of defendant's opposition brief, with plaintiff's reply brief due by 6/5/2017. Order signed by Magistrate Judge Erica P. Grosjean on 4/24/2017. (Rooney, M)

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7 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: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov 8 Attorneys for Defendant 1 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 FRESNO DIVISION 12 13 14 15 16 17 18 ERIC BRIAN THOMAS, Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:16-CV-01044-EPG STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, 21 that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for three 22 weeks from April 28, 2017, to May 19, 2017. This is Defendant’s first request for extension. 23 Good cause exists as counsel for Defendant had to take unanticipated medical leave to care of 24 her elderly mother and has had debilitating migraines, which necessitated additional time off. 25 Because of the unanticipated leave, counsel for Defendant has not had sufficient time to respond 26 to various pending matters that currently conflict with the current deadline of April 28, 2017 or 27 adequately research and analyze the issues presented by Plaintiff. Defendant respectfully 28 Joint Stipulation and Order re Extension of Time, Case No. 1:16-CV-01044-EPG 1 1 requests additional time to respond to Plaintiff’s Motion for Summary Judgment. Defendant 2 makes this request in good faith with no intention to unduly delay the proceedings. 3 4 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 5 6 Respectfully submitted, 7 8 Dated: April 21, 2017 /s/ *Cyrsu Safa (*as authorized by email on April 21, 2017) CYRUS SAFA Attorney for Plaintiff Dated: April 21, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 9 10 11 12 13 14 15 16 17 18 By /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant 19 20 21 22 23 24 25 26 27 28 Joint Stipulation and Order re Extension of Time, Case No. 1:16-CV-01044-EPG 2 ORDER 1 2 3 4 5 6 7 Based on the above stipulation and good cause appearing therein, the Court grants Defendant an extension of time to file her opposition to Plaintiff’s opening brief. Defendant’s opposition brief shall be filed no later than May 19, 2017. Plaintiff may file his reply brief no later than June 5, 2017. No further extensions of this deadline will be granted. IT IS SO ORDERED. 8 9 Dated: April 24, 2017 /s/ UNITED STATES MAGISTRATE JUDGE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Joint Stipulation and Order re Extension of Time, Case No. 1:16-CV-01044-EPG 3

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