Shiboyan v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 11/13/2017 ORDERING that defendant shall file her opposition to plaintiff's opening brief on or before 11/27/2017. Plaintiff's optional reply brief shall be due 12/18/2017. (Zignago, K.)

1
2
3
4
5
6
7
8
9

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
GINA TOMASELLI, CSBN 267090
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO

12
13

ASHOT SHIBOYAN,

14
15
16
17
18

v.

Plaintiff,

NANCY A. BERRYHILL,
Acting Commissioner of Social
Security,
Defendant.

)
) Case No. 2:16-cv-01152-KJN
)
) UNOPPOSED MOTION FOR SECOND
)
) EXTENSION OF TIME; ORDER
)
)
)
)

19

IT IS HEREBY STIPULATED, by and between Ashot Shiboyan (Plaintiff) and
20

Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and
21

through their respective counsel of record, that Defendant shall have an extension of
22

time of ten (10) days to file her Opposition to Plaintiff’s Opening Brief. The current due

23

date is November 13, 2017. The new date will be November 27, 2017, although
24

Defendant hopes to file the brief before that date. An extension of time is needed
25

because the attorney responsible for briefing is still working through a backlog of cases
26
27
28

-1-

1
2
3
4
5

due to having been out on medical leave. The office is extremely busy at this time,
particularly with the approaching holidays, such that her cases cannot be transferred.
This request is made in good faith with no intention to unduly delay the proceedings.
The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly, such that Plaintiff’s reply brief shall be due December 18, 2017.

6

Respectfully submitted,

7
8

Date: November 8, 2017

By: /s/ Geri Nadine Kahn*
GERI NADINE KAHN
Attorney for Plaintiff
(*As authorized by e-mail on November 8, 2017)

Date: November 8, 2017

PHILLIP A. TALBERT
United States Attorney

9
10
11
12
13

15

/s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

16

Attorneys for Defendant

14

17

ORDER

18
19

GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, IT IS SO

20

ORDERED. DEFENDANT SHALL FILE HER OPPOSITION TO PLAINTIFF’S

21

OPENING BRIEF ON OR BEFORE NOVEMBER 27, 2017. PLAINTIFF’S

22
23

OPTIONAL REPLY BRIEF SHALL BE DUE DECEMBER 18, 2017.

24

Dated: November 13, 2017

25
26
27
28

-2-