Kiser v. Commissioner of Social Security

Filing 24

JOINT STIPULATION FOR EXTENSION OF TIME AND ORDER, signed by Magistrate Judge Jeremy D. Peterson on 4/29/2019. (Case Management Deadline: 5/22/2019) (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 April 22, 2019 to May

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

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Defendant’s request for extension. Counsel for Defendant (Counsel) recently had multiple family

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deaths and has been out of the office caring for her elderly mother. In addition, last month,

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Counsel was terribly ill with the flu and pneumonia and was out of the office for two and half

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weeks on intermittent sick leave. Counsel also was out for her chronic migraines, which impair

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her vision. In addition, Counsel has over 100+ active matters, which require two or more

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dispositive motions per week until mid-June. Counsel fell behind on her heavy caseload as a
JS for Extension of Time,

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

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result of her unanticipated sick leave. Due to unexpected leave and heavy workload, Counsel

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respectfully requests additional time to adequately review the transcript and respond to the issues

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raised in Plaintiff’s Opening Brief. Defendant makes this request in good faith with no intention

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to unduly delay the proceedings. Defendant apologizes for the belated request for extension, but

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made this request as soon as reasonably practicable. 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: April 22, 2019

/s/ * Shellie Lott
(*as authorized by email on April 22, 2019)
SHELLIE LOTT
Attorney for Plaintiff

Dated: April 22, 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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ORDER

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

The court grants the requested extension and the Scheduling Order will be adjusted
accordingly.

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IT IS SO ORDERED.

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Dated:

April 29, 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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JS for Extension of Time,

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

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