Plummer v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 4/27/17 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED to 5/5/2017. (Kastilahn, A)

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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 an

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additional week from April 28, 2017, to May 5, 2017. Good cause exists to grant the extension.

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Counsel for Defendant had a recent unexpected medical emergency with her mother that

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required immediate medical attention. Counsel is the sole caregiver for her mother. Defendant

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is expected to be out of the office on April 28, 2017, the current deadline, in order to take her

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mother to the hospital.

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This is Defendant’s fourth request for extension. Defendant respectfully requests
additional time to respond to Plaintiff’s Motion for Summary Judgment in order to adequately
Joint Stipulation for Extension of Time; 2:16-CV-00753-AC

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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 27, 2017

/s/ *Jesse Kaplan
(*as authorized by email on April 27, 2017)
JESSE KAPLAN
Attorney for Plaintiff

Dated: April 27, 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: April 27, 2017

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

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