Fickardt v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 08/31/17 ORDERING that the due date for defendant to respond to the 10 Motion for Summary Judgment is EXTENDED to 09/05/17. (Benson, A.)

Download PDF
1 2 3 4 5 6 7 8 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration CAROLYN B. CHEN, CSBN 256628 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 CASEY FICKARDT, Plaintiff, 14 15 16 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, 17 Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-cv-02596-CMK STIPULATION AND ORDER FOR AN EXTENSION OF TIME OF 8 DAYS FOR DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 IT IS HEREBY STIPULATED, by and between the parties, through their respective 20 21 counsel of record, that Defendant shall have an extension of time of an additional 8 days to 22 respond to Plaintiff’s motion for summary judgment. This is the third continuance sought by 23 Defendant. The current due date is August 28, 2017. The new due date will be September 5, 24 2017. 25 There is good cause for this request. Since Defendant’s last request on July 25, 2017, 26 Defendant’s counsel had been diligently addressing her full workload including several district 27 court cases and one Equal Employment Opportunity Commission matter involving discovery and 28 another Equal Employment Opportunity Commission case involving briefing. Moreover, 1 1 between July 25, 2017 and August 28, 2017, Defendant’s counsel had additional unanticipated 2 matters that involved extensive briefing, including two district court decisions decided on July 3 31, 2017, and August 4, 2017, to which counsel needed to file objections or motions in response, 4 with deadlines that could not be extended. Despite counsel’s diligence in responding to the new 5 matters and her remaining workload, counsel was set back in addressing all her other cases, 6 including this one. Therefore, Defendant is respectfully requesting additional time up to and 7 including September 5, 2017, to fully review the record and research the issues presented by 8 Plaintiff’s motion for summary judgment in this case. This request is made in good faith with no 9 intention to unduly delay the proceedings. 10 11 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 12 13 Respectfully submitted, Date: August 28, 2017 14 15 s/ James S. Pi by C.Chen* (As authorized by e-mail on 8/28/2017) JAMES S. PI Attorneys for Plaintiff 16 17 18 CHARLES E. BINDER AND HARRY J. BINDER, ATTORNEYS AT LAW Date: August 28, 2017 19 PHILLIP A. TALBERT United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 20 21 22 Attorneys for Defendant 23 24 25 ORDER APPROVED AND SO ORDERED: 26 27 Dated: August 31, 2017 28 2

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?