Thomas v. Commissioner of Social Security

Filing 20

Stipulation and Order for extension of time for Defendant to file response to Plaintiffs Motion for Summary Judgment, signed by Magistrate Judge Erica P. Grosjean on 5/19/2017. ( Response due by 5/26/2017) (Rosales, O)

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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 one 22 week from May19, 2017, to May 26, 2017. This is Defendant’s second request for extension. 23 Good cause exists as counsel for Defendant is taking family medical leave on the date of the 24 current filing deadline for her mother’s surgery. Counsel for Defendant also has a pending Ninth 25 Circuit due on the same date of the filing deadline. Counsel for Defendant apologizes for the late 26 request due to unforeseen circumstances and unanticipated family medical leave. Counsel did 27 not have sufficient time to adequately research the issues raised in Plaintiff’s brief in time for the 28 current deadline. As such, Defendant respectfully requests additional time to respond to 1 1 Plaintiff’s Motion for Summary Judgment. Defendant makes this request in good faith with no 2 intention to unduly delay the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified 3 4 accordingly. 5 6 Respectfully submitted, 7 8 Dated: May 18, 2017 /s/ *Cyrsu Safa (*as authorized by email on May 18, 2017) CYRUS SAFA Attorney for Plaintiff Dated: May 18, 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 By 16 17 18 19 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant . 20 21 22 23 24 25 26 27 28 2 ORDER 1 2 3 4 5 For the reasons provided in the parties’ stipulation, good cause appears for an extension of time for responding to Plaintiff’s Motion for Summary Judgment for one week from May19, 2017, to May 26, 2017. All other deadlines are modified accordingly. IT IS SO ORDERED. 6 7 Dated: May 19, 2017 /s/ UNITED STATES MAGISTRATE JUDGE 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3

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