Martinez v. Commissioner of Social Security

Filing 25

ORDER signed by Magistrate Judge Craig M. Kellison on 9/12/2017 ORDERING 21 that the time for responding to Plaintiff's Motion for Summary Judgment filed by Joel Hernandez Martinez, is EXTENDED to 9/26/2017.(Reader, L)

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7 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: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker @SSA.gov 8 Attorneys for Defendant 1 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 14 15 16 17 18 JOEL HERNANDEZ MARTINEZ, Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) 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 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that 21 the time for responding to Plaintiff’s Motion for Summary Judgment be extended for 22 approximately 21 days from September 5, 2017 to September 26, 2017. This is Defendant’s 23 second request for extension. Good cause exists to grant Defendant’s request for extension. 24 Additional time is required as counsel for Defendant (Counsel) has been experiencing 25 debilitating chronic migraines and daily headaches that impairs her vision. Due to current 26 workload demands and shortened staff, Counsel currently has over 50+ active pending matters, 27 with two or more dispositive motions due per week until late October. As a result, Counsel had 28 to take intermittent and unanticipated medical leave which caused her to become behind on her Joint Stipulation for Extension of Time and PO; 2:16-CV-00101-CMK 1 1 caseload. Counsel apologizes for the belated nature of the request, but did not anticipate taking 2 additional medical leave due to her chronic migraines. Defendant respectfully requests 3 additional time in order to adequately assess the issues raised in Plaintiff’s Motion. Defendant 4 makes this request in good faith with no intention to unduly delay the proceedings. The parties 5 further stipulate that the Court’s Scheduling Order shall be modified accordingly. 6 7 Respectfully submitted, 8 9 Dated: September 5, 2017 /s/ *Robert C. Weems (*as authorized by email on September 5, 2017) ROBERT C. WEEMS Attorney for Plaintiff Dated: September 5, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 10 11 12 13 14 15 16 By 17 18 19 20 . 21 22 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant ORDER APPROVED AND SO ORDERED: 23 24 Dated: September 12, 2017 25 26 27 28 Joint Stipulation for Extension of Time and PO; 2:16-CV-00101-CMK 2

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