Martinez v. Commissioner of Social Security
Filing
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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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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
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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 21 days from September 5, 2017 to September 26, 2017. This is Defendant’s
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second 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) has been experiencing
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debilitating chronic migraines and daily headaches that impairs her vision. Due to current
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workload demands and shortened staff, Counsel currently has over 50+ active pending matters,
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with two or more dispositive motions due per week until late October. As a result, Counsel had
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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
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caseload. Counsel apologizes for the belated nature of the request, but did not anticipate taking
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additional medical leave due to her chronic migraines. Defendant respectfully requests
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additional time in order to adequately assess the issues raised in Plaintiff’s Motion. Defendant
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makes this request in good faith with no intention to unduly delay the proceedings. The parties
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further stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Respectfully submitted,
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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
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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: September 12, 2017
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Joint Stipulation for Extension of Time and PO; 2:16-CV-00101-CMK
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