Martinez v. Commissioner of Social Security

Filing 27

ORDER signed by Magistrate Judge Craig M. Kellison on 9/27/2017 ORDERING that Defendant's time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED to 10/4/2017.(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: [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 8 days from September 26, 2017 to October 4, 2017. This is Defendant’s third

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

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time is required as counsel for Defendant (Counsel) experienced an unexpected loss of a loved

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one on September 15, 2017. Counsel attended funeral and prayer services last week. Due to

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current workload demands and shortened staff, Counsel currently has over 50+ active pending

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matters, with two or more dispositive motions due per week until late October. Due to

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unexpected leave, Counsel became behind on her heavy caseload. Counsel apologizes for the
Joint Stipulation for Extension of Time and PO; 2:16-CV-00101-CMK
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belated nature of the request, but did not anticipate taking additional leave due to a recent and

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unexpected death of a loved one. Defendant respectfully requests additional time in order to

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adequately assess the issues raised in Plaintiff’s Motion. Defendant makes this request in good

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faith with no intention to unduly delay the proceedings. The parties further stipulate that the

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Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: September 25, 2017

/s/ *Robert C. Weems
(*as authorized by email on September 25, 2017)
ROBERT C. WEEMS
Attorney for Plaintiff

Dated: September 25, 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 27, 2017

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