Mason v. Commissioner of Social Security

Filing 18

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

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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 BEATRICE NA, CSBN 303390 Special Assistant United States Attorney Social Security Administration Office of the General Counsel 160 Spear St Ste 800 San Francisco, CA 94105 Telephone: (415) 977-8967 Facsimile: (415) 744-0134 E-mail: Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 ERICK A. MASON, 15 16 17 18 19 Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) Case No. 2:16-cv-02734-CKD ) ) JOINT STIPULATION AND ORDER FOR ) AN EXTENSION OF TIME ) ) ) ) ) ) ) ) 20 21 IT IS HEREBY STIPULATED, by and between the parties, through their respective 22 counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary 23 Judgment be extended from November 20, 2017 to December 11, 2017. This is Defendant’s 24 second request for an extension of time to respond to Plaintiff’s Motion for Summary Judgment. 25 Defendant requests this extension due to her counsel’s heavy workload. Defendant’s 26 counsel is currently responsible for conducting deposition of the Complainant in a personnel- 27 related litigation pending before the Equal Employment Opportunity Commission, and preparing 28 for a 2-day arbitration hearing that involves total of 11 witnesses taking place on November 29- 1 30, 2017. Defendant’s counsel is also responsible for a Social Security appeal before the United 2 States Court of Appeals for the Ninth Circuit that is due on November 27, 2017, and over 40 3 district court cases in variety of stages, including 6 other cases that require imminent briefing. 4 Defendant’s counsel respectfully requests this additional time to expend the necessary 5 time to review the record and to evaluate the issues Plaintiff raised, and to submit Defendant’s 6 response for review by this Court. 7 8 9 The parties further stipulate that all subsequent deadlines set forth in the Court’s Scheduling Order shall be extended accordingly. The parties stipulate in good faith, with no intent to prolong proceedings unduly. 10 Respectfully submitted, 11 Dated: November 16, 2017 /s/ Robert C. Weems* (* As authorized via email on November 16, 2017) ROBERT C. WEEMS 12 13 Attorney for Plaintiff 14 15 16 Dated: November 16, 2017 PHILLIP A. TALBERT United States Attorney 17 By: 18 19 /s/ Beatrice Na BEATRICE NA Special Assistant United States Attorney Attorneys for Defendant 20 21 ORDER 22 23 APPROVED AND SO ORDERED: 24 25 26 27 28 Dated: November 20, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE

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