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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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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LIZA JONES O/B/O AJA TERRY,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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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

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for two

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weeks from October 20, 2017 to November 3, 2017. This is Defendant’s second request for

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extension. Good cause exists to grant Defendant’s request for extension. Counsel sprained her

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hand and is currently on medical leave. Due to unexpected leave, additional time is required as

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Counsel for Defendant has over 50 active pending matters, of which require 2+ responses to

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dispositive motions per week. Due to current workload demands and shortened staff, Counsel

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needs additional time to adequately review the transcript and properly respond to Plaintiff’s

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Motion for Summary Judgment. Counsel apologizes for the belated nature of the request, but

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she did not expect taking unanticipated medical leave. Defendant makes this request in good

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faith with no intention to unduly delay the proceedings. The parties further stipulate that the

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Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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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

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By

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ORDER

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

APPROVED AND SO ORDERED.

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Dated: October 24, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE