Tunstall v. Commissioner of Social Security

Filing 18

Joint STIPULATION and ORDER for Extension of Time for Defendant to Respond to Plaintiff's Motion for Summary Judgment, signed by Magistrate Judge Barbara A. McAuliffe on 6/5/2018. Based on the parties' stipulation, and for cause shown, IT I S HEREBY ORDERED that Defendant shall have an extension of time to July 13, 2018, to file a response to Plaintiff's opening brief. All other deadlines set forth in the Court's Scheduling Order shall be extended accordingly. No further extensions of time shall be granted absent a showing of good cause. (Valdez, E)

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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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SACRAMENTO DIVISION

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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 June

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7, 2018 to July 13, 2018. This is Defendant’s second request for extension. Good cause exists

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to grant Defendant’s request for extension. Due to Counsel’s ongoing medical issues and

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unanticipated leave, Counsel respectfully requests additional time to respond to Plaintiff’s

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Motion for Summary Judgment, as she became behind on her heavy caseload. Counsel has over

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75+ pending social security cases, which require two or more dispositive motions a week until

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late June. Counsel also has a Ninth Circuit matter that requires additional levels of review,
JS for Extension of Time

Case No. 1:17-cv-00922-BAM

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several pending civil rights matters, which require imminent attention and investigation, and a

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legal opinion, which requires significant research for agency review. Defendant makes this

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request in good faith with no intention to unduly delay the proceedings. The parties further

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stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: June 4, 2018

s/ *Cyrus Safa
(*as authorized by email on June 4, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: June 4, 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
Based on the parties’ stipulation, and for cause shown, IT IS HEREBY ORDERED that

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Defendant shall have an extension of time to July 13, 2018, to file a response to Plaintiff’s

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opening brief. All other deadlines set forth in the Court’s Scheduling Order shall be extended

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accordingly. No further extensions of time shall be granted absent a showing of good cause.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

June 5, 2018

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time

Case No. 1:17-cv-00922-BAM

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