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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1 2 3 4 5 6 7 8 9 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: 415-977-8952 Facsimile: 415-744-0134 Email: Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 NICOLE ANN SAHAJ, 14 Plaintiff, 15 v. 16 17 18 NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. 19 ) Case No.: 2:16-cv-2563-CKD ) ) STIPULATION AND ORDER TO ) EXTEND BRIEFING SCHEDULE ) ) ) ) ) ) ) 20 21 IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to 22 extend Defendant’s time to file her summary judgment motion with the Court by 14 days to June 23 14, 2017, and that all other scheduling dates set forth in the Court’s Case Management Order 24 shall be extended accordingly. This is Defendant’s second request for an extension of time in 25 this matter and she requests it in good faith and without any intent to prolong proceedings 26 unduly. 27 There is good cause for this extension request because counsel for Defendant has 28 workload issues that preclude filing her summary judgment motion by May 31, 2017. In 1 particular, counsel for Defendant was reassigned an oral argument for a Social Security case 2 before the Ninth Circuit that occurred on May 18, 2017; given the time expended in the 3 preparations for this Ninth Circuit oral argument, counsel for Defendant requires additional time 4 to research and analyze the factual and legal issues presented in the instant case. Furthermore, 5 counsel for Defendant remains responsible for performing an extensive range of tasks over the 6 next month, including: reviewing the excerpts of record and drafting the Commissioner’s 7 answering brief in two Social Security cases before the Ninth Circuit; drafting briefs and 8 summary judgment motions and negotiating (or litigating) attorney fee matters pursuant to the 9 Equal Access to Justice Act before the district courts within the Seventh and Ninth Circuit; 10 conducting discovery, drafting substantive pleadings, and preparing for a hearing in personnel- 11 related litigation pending before the Merit Systems Protection Board; assisting with 12 implementing the terms of the class action settlement reached in Hart v. Berryhill (N.D.Cal. No. 13 3:15-cv-623-JST); and preparing training materials and conducting presentations to the Social 14 Security Administration’s Office of Disability Adjudication and Review. 15 16 Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay. 17 Respectfully submitted, 18 19 Date: May 24, 2017 LAW OFFICES OF LAWRENCE D. ROHLFING 20 By: 21 22 /s/ Asim H. Modi for Brian C. Shapiro* BRIAN C. SHAPIRO *Authorized by email on May 24, 2017 Attorney for Plaintiff 23 24 25 26 27 28 Date: May 24, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration By: 1 2 /s/ Asim H. Modi ASIM H. MODI Special Assistant United States Attorney Attorneys for Defendant 3 4 ORDER 5 6 APPROVED AND SO ORDERED. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: May 26, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE

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