R. v. Commissioner of Social Security
Filing
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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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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
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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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VERA RADOVA on behalf of ROMAN
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RADOVA
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Plaintiff,
vs.
NANCY A. BERRYHILL
Acting Commissioner of Social Security,
Defendant.
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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
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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 from
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October 27, 2017 to November 27, 2017. This is Defendant’s second request for extension.
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Good cause exists to grant Defendant’s request for extension. Additional time is required as
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counsel for Defendant sprained her right thumb. As a result, Counsel has been on unexpected
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medical leave. In addition, Counsel for Defendant has over 50+ active pending matters, of which
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require 2+ dispositive motions until end of December. As a result of Counsel’s medical leave,
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she is behind on her heavy caseload. In addition, Counsel for Plaintiff recently filed a
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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
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the agency. Defendant needs additional time to assess Plaintiff’s argumenta and properly
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respond to Plaintiff’s Motion for Summary Judgment or consider settlement options based on
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Counsel’s new authority provided on October 22, 2017. Counsel for Defendant apologizes for
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the belated nature of this request, but did not anticipate seeking an extension due to her recent
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hand sprain and medical leave. Defendant makes this request in good faith with no intention to
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unduly delay the proceedings. The parties further stipulate that the Court’s Scheduling Order
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shall be modified accordingly.
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Respectfully submitted,
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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
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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
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APPROVED AND SO ORDERED:
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Dated: October 24, 2017
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
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JS and PO for Extension of Time; 2:17-cv-00187-CKD
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