Hulsey v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 8/7/2017 ORDERING that Defendant shall have a first extension of time of 30 days to respond to 14 Motion for Summary Judgment and file her Cross-Motion for Summary Judgment. The new due date will be 9/3/2017. (Washington, S) Modified on 8/7/2017 (Washington, S).

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
JENNIFER A. KENNEY, CSBN 241625
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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LYNNE HULSEY,

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

Case No.: 2:16-CV-03057-AC
STIPULATION AND PROPOSED ORDER
FOR A FIRST EXTENSION OF 30 DAYS
FOR DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT AND FILE HER CROSSMOTION FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s Motion for

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Summary Judgment and file her Cross-Motion for Summary Judgment. The additional time is

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requested due to Defendant’s counsel’s exceptionally heavy workload at this time, including two

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employment law matters in active litigation, one pending before the pending Equal Employment

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Opportunity Commission and another before the Merit Systems Protection Board. In addition,

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Defendant’s counsel has seven other pending district court and Ninth Circuit cases with filing
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deadlines imminent. The additional time requested is needed to adequately research the issues
Stip. & Prop. Order to Extend 2:16-CV-03057-AC

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Plaintiff has presented. The current due date is August 4, 2017. The new due date will be

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September 3, 2017.

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

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Respectfully submitted,

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Dated: August 3, 2017

/s/ Josephine Gerrard
(as authorized by email)
JOSEPHINE GERRARD
Attorney for Plaintiff

Dated: August 3, 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/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant U.S. Attorney
Attorneys for Defendant

ORDER

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APPROVED AND SO ORDERED:
DATED: August 7, 2017

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Stip. & Prop. Order to Extend 2:16-CV-03057-AC

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