Terry v. Commissioner of Social Security

Filing 19

STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on 9/15/2017 ORDERING the Commissioner of Social Security to respond to the 17 Motion for Summary Judgment by 10/20/2017. (Michel, G.)

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7 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: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov 8 Attorneys for Defendant 1 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 14 15 16 17 18 LIZA JONES O/B/O AJA TERRY, Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-CV-02324-CKD JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, 21 that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for thirty 22 days from September 20, 2017 to October 20, 2017. This is Defendant’s first request for 23 extension. Good cause exists to grant Defendant’s request for extension. Counsel for Defendant 24 was on unexpected medical leave and became behind on her caseload. Additional time is 25 required as Counsel for Defendant has over 50 active pending matters, of which require 2+ 26 responses to dispositive motions per week until mid-October. Due to current workload demands 27 and shortened staff, Counsel needs additional time to adequately review the transcript and 28 properly respond to Plaintiff’s Motion for Summary Judgment. Defendant makes this request in 1 good faith with no intention to unduly delay the proceedings. The parties further stipulate that 2 the Court’s Scheduling Order shall be modified accordingly. 3 4 Respectfully submitted, 5 6 Dated: September 14, 2017 /s/ *Robert C. Weems (*as authorized by email on September 14, 2017) ROBERT C. WEEMS Attorney for Plaintiff Dated: September 14, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 7 8 9 10 11 12 13 By 14 15 16 ORDER 17 18 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant APPROVED AND SO ORDERED: 19 20 21 22 23 24 25 26 27 28 Dated: September 15, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE

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