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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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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TATYANA PLUMMER,
Plaintiff,

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vs.
NANCY A. BERRYHILL1,
Acting Commissioner of Social Security,

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Defendant.

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Case No.: 2:16-CV-00753-AC
JOINT STIPULATION 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,

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

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February 3, 2017, to March 6, 2017 due to current workload demands. Defendant currently has

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four othe pending responses due the same time as the current deadline and a Ninth Circuit

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responsive brief due to the U.S. Attorney’s Office thereafter. This is Defendant’s first request

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for extension. Defendant respectfully requests additional time to respond to Plaintiff’s Motion

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for Summary Judgment in order to adequately research and analyze the issues presented by

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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

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Plaintiff. Defendant makes this request in good faith with no intention to unduly delay the

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proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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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

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By

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/s/ Roya Massoumi
Roya Massoumi
Special Assistant U.S. Attorney
Of Counsel:
TINA L. NAICKER
Assistant Regional Counsel

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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DATED: January 26, 2017

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Joint Stipulation for Extension of Time; 2:16-CV-00753-AC

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