Kennon, Jr. v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 3/20/17 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is extended from 3/17/17 to 4/14/17.(Becknal, R)

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1 2 3 4 5 6 7 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CYNTHIA B. DE NARDI, CSBN 256770 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8961 Facsimile: (415) 744-0134 E-Mail: 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 JAMES OLLIE KENNON JR., 14 Plaintiff, 15 16 17 vs. NANCY A. BERRYHILL,1 Acting Commissioner of Social Security, Defendant. 18 19 ) Case No.: 2:16-CV-01951-AC ) ) STIPULATION AND PROPOSED ORDER ) FOR AN EXTENSION OF TIME ) ) ) ) ) ) ) ) IT IS HEREBY STIPULATED, by and between the parties, through their respective 20 counsel of record, that the time for responding to Plaintiff’s Motion for Summary Judgment be 21 extended from March 17, 2017 to April 14, 2017. This is Defendant’s second request for an 22 extension of time to respond to Plaintiff’s motion. Defendant respectfully requests this additional 23 time because the undersigned was preparing a voluminous document production in response to 24 an Equal Employment Opportunity Commission (EEOC) discovery matter, without paralegal 25 26 27 28 1 Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Acting Commissioner Carolyn W. Colvin as the defendant in this suit. No further action needs to be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). Stip. & Prop. Order for Ext..;2:16-cv-01951-AC 1 1 assistance, and preparing substantive pleadings in an EEOC case. The undersigned apologizes to 2 the Court for any inconvenience cause by this delay. 3 Respectfully submitted, 4 5 Dated: March 17, 2017 *s/Jonathan O. Pena (*as authorized via email on 3/17/17) JONATHAN O. PENA, ESQ. Attorney for Plaintiff Dated: March 17, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 6 7 8 9 10 11 12 By: 14 /s/ Cynthia B. De Nardi CYNTHIA B. DE NARDI Special Assistant U.S. Attorney 15 Attorneys for Defendant 13 16 17 APPROVED AND SO ORDERED: 18 DATED: March 20, 2017 19 20 21 22 23 24 25 26 27 28 Stip. & Prop. Order for Ext..;2:16-cv-01951-AC 2

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