Delarosa v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 4/11/2018 ORDERING a 21-Day Extension of Time for Defendant to respond to 18 MSJ and to file her Cross-Motion for Summary Judgment. Filing due by 5/3/2018. The Court's Scheduling Order shall be modified accordingly. (Fabillaran, J)

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MCGREGOR W. SCOTT
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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JON DELAROSA,

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Plaintiff,
vs.
NANCY A. BERRYHILL,
Deputy Commissioner for Operations,
performing the duties and functions not
reserved to the Commissioner of Social
Security,

Case No.: 2:17-CV-00423-AC
STIPULATION AND PROPOSED ORDER
FOR A FIRST EXTENSION OF 21 DAYS
FOR DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT AND FILE HER CROSSMOTION FOR SUMMARY JUDGMENT

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Defendant.

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

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that Defendant shall have a first extension of time of 21 days to respond to Plaintiff’s Motion for

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Summary Judgment and file her Cross-Motion for Summary Judgment. This extension is

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requested because Defendant’s counsel is experiencing an exceptionally heavy workload at this

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time. In addition to several district court filing deadlines this month, Defendant’s counsel was

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recently assigned to represent the Social Security Administration in a three-day employment law
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hearing before the Equal Employment Opportunity Commission. The additional time requested
Stip. & Prop. Order to Extend 2:17-CV-00423-AC

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will enable Defendant to adequately research the issues presented in this case. The current due

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date is April 12, 2018. The new due date will be May 3, 2018.

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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: April 9, 2018

/s/ Robert Weems*
(*as authorized by email)
ROBERT WEEMS
Attorney for Plaintiff

Dated: April 9, 2018

MCGREGOR W. SCOTT
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: April 11, 2018

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Stip. & Prop. Order to Extend 2:17-CV-00423-AC

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