Plummer v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 4/20/2017. ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED from 4/20/2017 to 4/28/2017. (Washington, S)

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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 April

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20, 2017, to April 28, 2017 due to counsel for Defendant’s unanticipated medical leave. Good

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cause exists to grant the extension. Counsel for Defendant was out of the office the week prior

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due to take care of her elderly mother. In addition, counsel has been suffering from debilitating

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migraines, which has caused Defendant to take unanticipated medical leave for herself and her

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mother. In addition, counsel needs additional time in order to complete the agency’s review

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process for newer attorneys.

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

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This is Defendant’s third request for extension. Defendant respectfully requests

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additional time to respond to Plaintiff’s Motion for Summary Judgment in order to adequately

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research and analyze the issues presented by Plaintiff. Defendant makes this request in good

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faith with no intention to unduly delay the proceedings. Defendant will diligently meet the new

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deadline.

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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: April 20, 2017

/s/ *Jesse Kaplan
(*as authorized by email on April 19, 2017)
JESSE KAPLAN
Attorney for Plaintiff

Dated: April 20, 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:
DATED: April 20, 2017

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

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