Kiser v. Commissioner of Social Security

Filing 20

JOINT STIPULATION FOR EXTENSION OF TIME AND ORDER, signed by Magistrate Judge Jeremy D. Peterson on 03/25/2019. (Case Management Deadline: 4/22/2019)(Martin-Gill, S)

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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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FRESNO DIVISION

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DANIEL W. KISER,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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) Case No.: 1:18-cv-00518-JDP
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) JOINT STIPULATION FOR EXTENSION
) OF TIME AND ORDER
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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 Opening Brief be extended from March 22, 2019 to

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April 22, 2019. This is Defendant’s first request for extension. Good cause exists to grant

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Defendant’s request for extension. Counsel has been on intermittent sick leave with the

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flu/pneumonia for the past couple weeks. In addition, Counsel also has over 80+ active social

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security matters, which require two or more dispositive motions per week until mid-April. Due

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to heavy caseload and unexpected leave, Counsel needs additional time to adequately review the

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transcript and properly respond to Plaintiff’s Opening Brief. The parties further stipulate that the

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JS for Extension of Time,

Case No. 1:18-cv-00518-JDP

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Court’s Scheduling Order shall be modified accordingly. Defendant makes this request in good

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faith with no intention to unduly delay the proceedings.

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Respectfully submitted,

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Dated: March 21, 2019

/s/ * Langley Kreuze
(*as authorized by email by C. Hodges on March 21, 2019)
LANGLEY KREUZE
Attorney for Plaintiff

Dated: March 21, 2019

MCGREGOR W. SCOTT
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
ORDER

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IT IS SO ORDERED.

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Dated:

March 25, 2019
UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time,

Case No. 1:18-cv-00518-JDP

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