Terry v. Commissioner of Social Security
Filing
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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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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
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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 November 3, 2017 to November 17, 2017. This is Defendant’s third request for
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extension. Good cause exists to grant Defendant’s request for extension. Counsel was on
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intermittent medical leave due to re-injuring her sprained right hand. As a result, Counsel had to
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take additional leave. Due to unanticipated medical leave, Counsel needs additional time as she
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has over 60 active pending matters, of which require 2+ responses to dispositive motions per
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week. Due to high workload demands and shortened staff due to budget constraints, 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 a longer recovery period for her recent hand injury and taking
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additional leave. Defendant makes this request in good faith with no intention to unduly delay
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the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be
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modified accordingly.
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Respectfully submitted,
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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
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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: November 7, 2017
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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
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