Spalliero v. Commissioner of Social Security

Filing 19

Joint STIPULATION and ORDER for Extension of Time for Defendant to Respond to Plaintiff's Motion for Summary Judgment: that Defendant shall have a 30-day extension, or until July 24, 2017, in which to file an Opposition to Plaintiff's Opening Brief; and that all other deadlines set forth in the Case Management Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 6/20/2017. (Herman, H)

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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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NICK ANGELO SPALLIERO,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 1:16-CV-01387-BAM
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

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approximately thirty days from June 23, 2017 to July 24, 2017. This is Defendant’s first request

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

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required as counsel for Defendant has been out of the office on medical leave for herself and to

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take care of her elderly mother, who had surgery in late May. Due to unanticipated medical

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leave, Counsel for Defendant became behind on her caseload. Due to current workload demands

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and shortened staff, Counsel currently has over 50+ active pending matters, with two or more

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dispositive motions due per week until mid-July. Defendant makes this request in good faith
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with no intention to unduly delay the proceedings. The parties further stipulate that the Court’s

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Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: June 19, 2017

/s/ *Cyrus Safa
(*as authorized by email on June 19, 2017)
CYRUS SAFA
Attorney for Plaintiff

Dated: June 19, 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

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ORDER

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Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY

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ORDERED, that Defendant shall have a 30-day extension, or until July 24, 2017, in which to file

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an Opposition to Plaintiff’s Opening Brief; and that all other deadlines set forth in the Case

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Management Order shall be extended accordingly.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

June 20, 2017

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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