Terry v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 10/24/2017 ORDERING the Commissioner of Social Security to respond to the 17 Motion for Summary Judgment by 11/3/2017. (Washington, S)

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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 two 22 weeks from October 20, 2017 to November 3, 2017. This is Defendant’s second request for 23 extension. Good cause exists to grant Defendant’s request for extension. Counsel sprained her 24 hand and is currently on medical leave. Due to unexpected leave, additional time is required as 25 Counsel for Defendant has over 50 active pending matters, of which require 2+ responses to 26 dispositive motions per week. Due to current workload demands and shortened staff, Counsel 27 needs additional time to adequately review the transcript and properly respond to Plaintiff’s 28 Motion for Summary Judgment. Counsel apologizes for the belated nature of the request, but 1 she did not expect taking unanticipated medical leave. Defendant makes this request in good 2 faith with no intention to unduly delay the proceedings. The parties further stipulate that the 3 Court’s Scheduling Order shall be modified accordingly. 4 5 Respectfully submitted, 6 7 Dated: October 20, 2017 /s/ *Robert C. Weems (*as authorized by email on October 20, 2017) ROBERT C. WEEMS Attorney for Plaintiff Dated: October 20, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 8 9 10 11 12 13 14 By 15 16 17 ORDER 18 19 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant APPROVED AND SO ORDERED. 20 21 22 23 24 25 26 27 28 Dated: October 24, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE

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