Terry v. Commissioner of Social Security

Filing 23

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 11/7/2017 ORDERING that the time for responding to plaintiff's motion for summary judgment is EXTENDED to 11/17/2017. (Zignago, K.)

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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 November 3, 2017 to November 17, 2017. This is Defendant’s third request for 23 extension. Good cause exists to grant Defendant’s request for extension. Counsel was on 24 intermittent medical leave due to re-injuring her sprained right hand. As a result, Counsel had to 25 take additional leave. Due to unanticipated medical leave, Counsel needs additional time as she 26 has over 60 active pending matters, of which require 2+ responses to dispositive motions per 27 week. Due to high workload demands and shortened staff due to budget constraints, Counsel 28 needs additional time to adequately review the transcript and properly respond to Plaintiff’s 1 Motion for Summary Judgment. Counsel apologizes for the belated nature of the request, but 2 she did not expect taking a longer recovery period for her recent hand injury and taking 3 additional leave. Defendant makes this request in good faith with no intention to unduly delay 4 the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be 5 modified accordingly. 6 7 Respectfully submitted, 8 9 Dated: November 2, 2017 /s/ *Robert C. Weems (*as authorized by email on November 2, 2017) ROBERT C. WEEMS Attorney for Plaintiff Dated: November, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 10 11 12 13 14 15 16 By 17 18 19 ORDER 20 21 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant APPROVED AND SO ORDERED: 22 23 24 25 26 27 28 Dated: November 7, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE

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