Martinez v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 7/26/17: The time for responding to Plaintiff's Motion for Summary Judgment is extended from August 3, 2017 to September 5, 2017.(Kaminski, H)

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PHILLIP A. TALBERT
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: Tina.Naicker @SSA.gov

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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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JOEL HERNANDEZ MARTINEZ,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-CV-00101-CMK
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, that

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the time for responding to Plaintiff’s Motion for Summary Judgment be extended for

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approximately thirty (30) days from August 3, 2017 to September 5, 2017. This is Defendant’s

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first request for extension. Good cause exists to grant Defendant’s request for extension.

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Additional time is required as counsel for Defendant (Counsel) was unexpectedly out of the

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office last week due to food poisoning and had a car accident last week, which also resulted in

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unexpected time out of the office. Due to current workload demands and shortened staff,

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Counsel currently has over 50+ active pending matters, with two or more dispositive motions

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due per week until late August. Due to the unexpected life events, Counsel became behind on
Joint Stipulation for Extension of Time and PO; 2:16-CV-00101-CMK
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her caseload. Defendant respectfully requests additional time in order to adequately assess and

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respond to Plaintiff’s Motion. Defendant makes this request in good faith with no intention to

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unduly delay the proceedings. The parties further stipulate that the Court’s Scheduling Order

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shall be modified accordingly.

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Respectfully submitted,

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Dated: July 24, 2017

/s/ *Robert C. Weems
(*as authorized by email on July 24, 2017)
ROBERT C. WEEMS
Attorney for Plaintiff

Dated: July 24, 2017

PHILLIP A. TALBERT
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
APPROVED AND SO ORDERED:

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Dated: July 26, 2017

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Joint Stipulation for Extension of Time and PO; 2:16-CV-00101-CMK
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