Tunstall v. Commissioner of Social Security

Filing 16

Joint STIPULATION and ORDER for Extension of Time for Defendant to Respond to Plaintiff's Motion for Summary Judgment: that Defendant shall have an extension of time, to and including June 7, 2018, in which to file a response Plaintiff's Opening Brief; and that all other deadlines set forth in the Courts Scheduling Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 5/3/2018. (Herman, H)

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MCGREGOR W. SCOTT
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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YVONNE JANETTA TUNSTALL,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security
Defendant.

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Case No.: 1:17-cv-00922-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 from May

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7, 2018 to June 7, 2018. This is Defendant’s first request for extension. Good cause exists to

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grant Defendant’s request for extension. Counsel has been on intermittent medical leave due to

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her chronic migraines, which impair her vision. Counsel has over 75+ pending social security

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cases, which require two or more dispositive motions a week until late June. Counsel also has

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Ninth Circuit matters that requires additional levels of review and three pending civil rights

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matters, which require imminent attention and investigation. Due to current workload demands

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and unanticipated leave, Counsel became behind on her heavy caseload and needs additional

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time to adequately review the transcript and properly respond to Plaintiff’s Motion for Summary

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Judgment. Defendant makes this request in good faith with no intention to unduly delay the

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proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified

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accordingly.

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Respectfully submitted,

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Dated: May 2, 2018

s/ *Cyrus Safa
(*as authorized by email on May 2, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: May 2, 2018

McGREGOR W. SCOTT
Acting 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 an extension of time, to and including June 7, 2018, in

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which to file a response Plaintiff’s Opening Brief; and that all other deadlines set forth in the

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Court’s Scheduling Order shall be extended accordingly.

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IT IS SO ORDERED.

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Dated:

May 3, 2018

/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE