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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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: [phone]
Facsimile: [phone]
E-mail: [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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ERICK A. MASON,

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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
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant’s time for responding to Plaintiff’s Motion for Summary

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Judgment be extended from November 20, 2017 to December 11, 2017. This is Defendant’s

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second request for an extension of time to respond to Plaintiff’s Motion for Summary Judgment.

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Defendant requests this extension due to her counsel’s heavy workload. Defendant’s

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counsel is currently responsible for conducting deposition of the Complainant in a personnel-

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related litigation pending before the Equal Employment Opportunity Commission, and preparing

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for a 2-day arbitration hearing that involves total of 11 witnesses taking place on November 29-

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30, 2017. Defendant’s counsel is also responsible for a Social Security appeal before the United

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States Court of Appeals for the Ninth Circuit that is due on November 27, 2017, and over 40

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district court cases in variety of stages, including 6 other cases that require imminent briefing.

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Defendant’s counsel respectfully requests this additional time to expend the necessary

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time to review the record and to evaluate the issues Plaintiff raised, and to submit Defendant’s

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response for review by this Court.

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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.

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Respectfully submitted,

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Dated: November 16, 2017

/s/ Robert C. Weems*
(* As authorized via email on November 16, 2017)
ROBERT C. WEEMS

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Attorney for Plaintiff

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Dated: November 16, 2017

PHILLIP A. TALBERT
United States Attorney

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By:

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/s/ Beatrice Na
BEATRICE NA
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: November 20, 2017

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE