Plummer v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 3/1/2017 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED from 3/6/2017 to 4/20/2017. (Zignago, K.)

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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: [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,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
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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March 6, 2017, to April 20, 2017 due to current workload demands. Defendant has a Ninth

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Circuit brief due on or around the same time as the current deadline. In addition, counsel for

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Defendant needs additional time to complete the agency’s review process for new attorneys, who

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scheduled to be on leave from March 10-21, 2017. This is Defendant’s second request for

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

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

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Defendant makes this request in good faith with no intention to unduly delay the proceedings.
Joint Stipulation for Extension of Time; 2:16-CV-00753-AC

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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: February 28, 2017

/s/ *Jesse Kaplan
(*as authorized by email on February 21, 2017)
JESSE KAPLAN
Attorney for Plaintiff

Dated: February 28, 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

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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: March 1, 2017

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

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