R. v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 10/24/2017 ORDERING that the date for defendant to respond the plaintiff's 17 Motion for Summary Judgment is EXTENDED to 11/27/2017. (Washington, S)

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7 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: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov 8 Attorneys for Defendant 1 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 VERA RADOVA on behalf of ROMAN 14 RADOVA 15 16 17 18 Plaintiff, vs. NANCY A. BERRYHILL Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-00187-CKD JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JDUGMENT 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, 21 that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from 22 October 27, 2017 to November 27, 2017. This is Defendant’s second request for extension. 23 Good cause exists to grant Defendant’s request for extension. Additional time is required as 24 counsel for Defendant sprained her right thumb. As a result, Counsel has been on unexpected 25 medical leave. In addition, Counsel for Defendant has over 50+ active pending matters, of which 26 require 2+ dispositive motions until end of December. As a result of Counsel’s medical leave, 27 she is behind on her heavy caseload. In addition, Counsel for Plaintiff recently filed a 28 supplemental document on October 22, 2017, which necessitates further review by Counsel and JS and PO for Extension of Time; 2:17-cv-00187-CKD 1 1 the agency. Defendant needs additional time to assess Plaintiff’s argumenta and properly 2 respond to Plaintiff’s Motion for Summary Judgment or consider settlement options based on 3 Counsel’s new authority provided on October 22, 2017. Counsel for Defendant apologizes for 4 the belated nature of this request, but did not anticipate seeking an extension due to her recent 5 hand sprain and medical leave. Defendant makes this request in good faith with no intention to 6 unduly delay the proceedings. The parties further stipulate that the Court’s Scheduling Order 7 shall be modified accordingly. 8 Respectfully submitted, 9 10 Dated: October 23, 2017 s/ *Jesse Kaplan (*as authorized by email on October 23, 2017) JESSE KAPLAN Attorney for Plaintiff Dated: October 23, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 11 12 13 14 15 16 17 By 18 19 20 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant ORDER 21 APPROVED AND SO ORDERED: 22 23 24 25 Dated: October 24, 2017 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 26 27 28 JS and PO for Extension of Time; 2:17-cv-00187-CKD 2

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