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.)
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
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?