West v. Commissioner of Social Security

Filing 27

STIPULATION and ORDER GRANTING the parties' request for Defendant to have a 30-day extension of time, from October 23, 2017, until November 22, 2017, to respond to Plaintiff's Motion for Summary Judgment. All other dates in the Court's Scheduling Order shall be extended accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 10/18/2017. (Rooney, M)

1
2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT

9
EASTERN DISTRICT OF CALIFORNIA
10
11

BARRY DANA WEST,

12
13
14
15

Case No.: 1:16-cv-01377-EPG

Plaintiff,

STIPULATION & ORDER FOR
EXTENSION OF TIME

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

16
17
18
IT IS HEREBY STIPULATED, by and between the parties through their respective
19
20
21
22
23

counsel of record, that Defendant shall have a 30-day extension of time, from October 23, 2017
until November 22, 2017, to respond to Plaintiff’s Motion for Summary Judgment. All other
dates in the Court’s Scheduling Order shall be extended accordingly.
This is Defendant’s first request for an extension of time. Defendant respectfully submits

24

that good cause exists for the requested extension because additional time is needed to review

25

and evaluate the administrative record, to consider the issues raised in Plaintiff’s Motion, to

26

accommodate Defendant’s counsel’s competing workload demands, including an increase in the

27

number of cases requiring briefing, and to determine whether options exist for settlement.

28

Plaintiff does not oppose Defendant’s request for an extension of time.

1

1
2

Respectfully submitted,
Dated: October 17, 2017

3

CERNEY KREUZE & LOTT, LLP
By: /s/ Shellie Lott*
SHELLIE LOTT
Attorneys for Plaintiff
[*As authorized by e-mail on Oct. 17, 2017]

4
5
6
7
8
9
10

Dated: October 18, 2017

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

11
12
13

By: /s/ Margaret Branick-Abilla
___
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

2

1
2

ORDER
Based on the above stipulation by the parties, Defendant shall have a 30-day extension of

3

time, from October 23, 2017 until November 22, 2017, to respond to Plaintiff’s Motion for

4

Summary Judgment. All other dates in the Court’s Scheduling Order shall be extended

5

accordingly.

6
7

IT IS SO ORDERED.

8
9

Dated:

October 18, 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

3