Sahaj v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/26/2017 ORDERING that defendant's time to file her summary judgment is EXTENDED to 6/14/2017. (Zignago, K.)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
Email: [e-mail]
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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NICOLE ANN SAHAJ,

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Plaintiff,

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v.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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) Case No.: 2:16-cv-2563-CKD
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) STIPULATION AND ORDER TO
) EXTEND BRIEFING SCHEDULE
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to

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extend Defendant’s time to file her summary judgment motion with the Court by 14 days to June

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14, 2017, and that all other scheduling dates set forth in the Court’s Case Management Order

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shall be extended accordingly. This is Defendant’s second request for an extension of time in

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this matter and she requests it in good faith and without any intent to prolong proceedings

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unduly.

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There is good cause for this extension request because counsel for Defendant has

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workload issues that preclude filing her summary judgment motion by May 31, 2017. In

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particular, counsel for Defendant was reassigned an oral argument for a Social Security case

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before the Ninth Circuit that occurred on May 18, 2017; given the time expended in the

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preparations for this Ninth Circuit oral argument, counsel for Defendant requires additional time

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to research and analyze the factual and legal issues presented in the instant case. Furthermore,

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counsel for Defendant remains responsible for performing an extensive range of tasks over the

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next month, including: reviewing the excerpts of record and drafting the Commissioner’s

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answering brief in two Social Security cases before the Ninth Circuit; drafting briefs and

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summary judgment motions and negotiating (or litigating) attorney fee matters pursuant to the

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Equal Access to Justice Act before the district courts within the Seventh and Ninth Circuit;

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conducting discovery, drafting substantive pleadings, and preparing for a hearing in personnel-

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related litigation pending before the Merit Systems Protection Board; assisting with

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implementing the terms of the class action settlement reached in Hart v. Berryhill (N.D.Cal. No.

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3:15-cv-623-JST); and preparing training materials and conducting presentations to the Social

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Security Administration’s Office of Disability Adjudication and Review.

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Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused
by this delay.

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Respectfully submitted,

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Date: May 24, 2017

LAW OFFICES OF LAWRENCE D.
ROHLFING

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By:
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/s/ Asim H. Modi for Brian C. Shapiro*
BRIAN C. SHAPIRO
*Authorized by email on May 24, 2017
Attorney for Plaintiff

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Date: May 24, 2017

PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

By:

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/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.

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Dated: May 26, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE