Plummer v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 01/26/17 ORDERING that defendant's due date for the response to plaintiff's Motion for Summary Judgment is EXTENDED to 03/06/17. (Benson, A)

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7 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration ROYA MASSOUMI, CSBN 242697 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8957 Facsimile: (415) 744-0134 E-Mail: 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 TATYANA PLUMMER, Plaintiff, 14 15 16 vs. NANCY A. BERRYHILL1, Acting Commissioner of Social Security, 17 Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-CV-00753-AC JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, 20 21 that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from 22 February 3, 2017, to March 6, 2017 due to current workload demands. Defendant currently has 23 four othe pending responses due the same time as the current deadline and a Ninth Circuit 24 responsive brief due to the U.S. Attorney’s Office thereafter. This is Defendant’s first request 25 for extension. Defendant respectfully requests additional time to respond to Plaintiff’s Motion 26 for Summary Judgment in order to adequately research and analyze the issues presented by 27 1 28 Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Acting Commissioner Carolyn W. Colvin as the defendant in this suit. No further action needs to be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). Joint Stipulation for Extension of Time; 2:16-CV-00753-AC 1 1 Plaintiff. Defendant makes this request in good faith with no intention to unduly delay the 2 proceedings. 3 4 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 5 Respectfully submitted, 6 7 Dated: January 25, 2017 /s/ *Jesse Kaplan (*as authorized by email on January 25, 2017) JESSE KAPLAN Attorney for Plaintiff Dated: January 25, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 8 9 10 11 12 13 14 By 15 16 17 /s/ Roya Massoumi Roya Massoumi Special Assistant U.S. Attorney Of Counsel: TINA L. NAICKER Assistant Regional Counsel 18 19 Attorneys for Defendant 20 ORDER 21 22 APPROVED AND SO ORDERED: 23 24 DATED: January 26, 2017 25 26 27 28 Joint Stipulation for Extension of Time; 2:16-CV-00753-AC 2

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