Cole v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 4/17/17 ORDERING that Defendant's time for responding to Plaintiff's Motion for Summary Judgment be EXTENDED from 4/14/17 to 5/30/2017.(Mena-Sanchez, L)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
BEATRICE NA, CSBN 303390
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
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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TIMESHA COLE,

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Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

) Case No. 2:16-cv-01597-KJN
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) JOINT STIPULATION AND PROPOSED
) ORDER FOR AN EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary

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Judgment be extended from April 14, 2017 to May 30, 2017 (May 29, 2017 is a holiday). This is

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Defendant’s first request for an extension of time to respond to Plaintiff’s Motion for Summary

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Judgment.

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Defendant requests this extension due to her counsel’s heavy workload. Defendant’s

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counsel is currently responsible for conducting discovery in a personnel-related litigation

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pending before the Equal Employment Opportunity Commission (EEOC), which requires review

Joint Stip. & Prop. Order for Ext.; 2:16-cv-1597-KJN

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of Complainant’s responses to agency’s discovery requests and numerous documents in order to

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investigate the relevant facts, in addition to preparing for a deposition. Defendant’s counsel is

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also responsible for an appellate brief for a Social Security case in the United States Court of

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Appeals for the Ninth Circuit, a bankruptcy case before the United States Bankruptcy Court for

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the Central District of California, and a representative sanctions matter, in addition to at least 35

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district court cases in a variety of stages.

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Defendant’s counsel respectfully requests this additional time to expend the necessary

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time to review the 644-page record and to evaluate the issues Plaintiff raised, and to submit

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Defendant’s response to Plaintiff’s motion for review by this Court.

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The parties further stipulate that all subsequent deadlines set forth in the Court’s
Scheduling Order shall be extended accordingly.
The parties stipulate in good faith, with no intent to prolong proceedings unduly.

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Respectfully submitted,

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Dated: April 11, 2017

/s/ Kelsey Brown*
(* As authorized via email on April 11, 2017)
KELSEY BROWN

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Attorney for Plaintiff

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Dated: April 11, 2017

PHILLIP A. TALBERT
United States Attorney

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By:

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/s/ Beatrice Na
BEATRICE NA
Special Assistant United States 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 17, 2017

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Joint Stip. & Prop. Order for Ext.; 2:16-cv-1597-KJN

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