Terry v. Commissioner of Social Security

Filing 25

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 11/20/17: The time for responding to Plaintiff's Motion for Summary Judgment shall be extended for one weeks from November 17, 2017 to November 24, 2017. (Kaminski, H)

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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 one

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weeks from November 17, 2017 to November 24, 2017. This is Defendant’s fourth request for

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extension. Good cause exists to grant Defendant’s request for extension. Counsel is currently

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sick and is out on leave. Due to unanticipated medical leave, Counsel needs additional time to

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adequately review the transcript and properly respond to Plaintiff’s Motion for Summary

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Judgment. Counsel apologizes for the belated nature of the request, but she did not expect

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taking additional leave. Defendant makes this request in good faith with no intention to unduly

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delay 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 17, 2017

/s/ *Robert C. Weems
(*as authorized by email on November 17, 2017)
ROBERT C. WEEMS
Attorney for Plaintiff

Dated: November 17, 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 20, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE