Wheeler v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 6/6/17: The time for responding to Plaintiff's Motion for Summary Judgment shall be extended from May 30, 2017 to June 30, 2017. (Kaminski, H)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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STEPHANIE WHEELER,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:16-CV-02827-AC
STIPULATION AND PROPOSED ORDER
FOR EXTENSION OF TIME FOR
DEFENDANT TO FILE RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended for two

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weeks from May 30, 2017 to June 30, 2017. This is Defendant’s first request for extension.

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Good cause exists to grant Defendant’s request for extension. Additional time is required

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because counsel for Defendant had to take family medical leave to care for her mother who had

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surgery last week. Due to unanticipated scheduled leave, counsel for Defendant did not have

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sufficient time to adequately research, analyze and respond to the issues presented by Plaintiff.

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Defendant respectfully requests additional time to respond to Plaintiff’s Motion for Summary

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Judgment. Defendant makes this request in good faith with no intention to unduly delay the
Joint Stipulation and PO for Extension of Time; 2:16-CV-02827-AC

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proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified

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accordingly.

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Respectfully submitted,

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Dated: May 24, 2017

/s/ *Joshua B. Kons
(*as authorized by email on May 24, 2017)
JOSHUA B. KONS
Attorney for Plaintiff

Dated: May 24, 2017

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

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER
APPROVED AND SO ORDERED:

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DATED: June 6, 2017

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Joint Stipulation and PO for Extension of Time; 2:16-CV-02827-AC

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