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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1 2 3 4 5 6 7 8 9 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: (415) 977-8967 Facsimile: (415) 744-0134 E-mail: Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 TIMESHA COLE, 15 16 17 18 Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, 19 Defendant. ) Case No. 2:16-cv-01597-KJN ) ) JOINT STIPULATION AND PROPOSED ) ORDER FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) 20 21 IT IS HEREBY STIPULATED, by and between the parties, through their respective 22 counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary 23 Judgment be extended from April 14, 2017 to May 30, 2017 (May 29, 2017 is a holiday). This is 24 Defendant’s first request for an extension of time to respond to Plaintiff’s Motion for Summary 25 Judgment. 26 Defendant requests this extension due to her counsel’s heavy workload. Defendant’s 27 counsel is currently responsible for conducting discovery in a personnel-related litigation 28 pending before the Equal Employment Opportunity Commission (EEOC), which requires review Joint Stip. & Prop. Order for Ext.; 2:16-cv-1597-KJN 1 1 of Complainant’s responses to agency’s discovery requests and numerous documents in order to 2 investigate the relevant facts, in addition to preparing for a deposition. Defendant’s counsel is 3 also responsible for an appellate brief for a Social Security case in the United States Court of 4 Appeals for the Ninth Circuit, a bankruptcy case before the United States Bankruptcy Court for 5 the Central District of California, and a representative sanctions matter, in addition to at least 35 6 district court cases in a variety of stages. 7 Defendant’s counsel respectfully requests this additional time to expend the necessary 8 time to review the 644-page record and to evaluate the issues Plaintiff raised, and to submit 9 Defendant’s response to Plaintiff’s motion for review by this Court. 10 11 12 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. 13 Respectfully submitted, 14 Dated: April 11, 2017 /s/ Kelsey Brown* (* As authorized via email on April 11, 2017) KELSEY BROWN 15 16 Attorney for Plaintiff 17 18 Dated: April 11, 2017 PHILLIP A. TALBERT United States Attorney 19 By: 21 /s/ Beatrice Na BEATRICE NA Special Assistant United States Attorney 22 Attorneys for Defendant 20 23 24 ORDER 25 APPROVED AND SO ORDERED: 26 Dated: April 17, 2017 27 28 Joint Stip. & Prop. Order for Ext.; 2:16-cv-1597-KJN 2

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