Kiser v. Commissioner of Social Security

Filing 30

AMENDED JOINT STIPULATION and ORDER Granting Extension of Time for Defendant to Respond to Plaintiff's Opening Brief signed by Magistrate Judge Jeremy D. Peterson on 06/11/2019. (Flores, 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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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
AMENDED JOINT STIPULATION FOR
EXTENSION OF TIME AND ORDER
FOR EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S OPENING BRIEF.

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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 June 7, 2019 to June

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11, 2019. This is Defendant’s fourth request for extension. Good cause exists to grant

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Defendant’s request for extension. As the Court is aware, Counsel for Defendant (Counsel) had

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multiple family tragedies last month, including the death of her two cousins, and uncle, and a

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family friend. Counsel has also been taking care of her elderly mother, who had surgery in late

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May and another follow up surgery this week, including taking her to a follow-up appointment

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on the date of the current filing deadline. In addition, Counsel has over 100+ active matters,

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which require two or more dispositive motions per week until mid-July. As such, Counsel
JS for Extension of Time,

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

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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: June 7, 2019

/s/ * Shellie Lott
(*as authorized by email on June 7, 2019)
SHELLIE LOTT
Attorney for Plaintiff

Dated: June 7, 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

Approved.

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IT IS SO ORDERED.

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Dated:

June 11, 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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