Foster v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 11/28/17: The time for responding to Plaintiff's Motion for Summary Judgment shall be extended to December 22, 2017.(Kaminski, H)

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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 DIMITRIUS FOSTER, 14 Plaintiff, 15 16 17 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-00439-CMK JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 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 for thirty 22 days from November 22, 2017 to December 22, 2017. This is Defendant’s first request for 23 extension. Good cause exists to grant Defendant’s request for extension. Counsel for Defendant 24 was on unexpected medical leave and became behind on her caseload. Additional time is 25 required as Counsel for Defendant has over 75 active pending matters, of which require 2+ 26 responses to dispositive motions per week until early-January. Due to current workload demands 27 and shortened staff, Counsel needs additional time to adequately review the transcript and 28 properly respond to Plaintiff’s Motion for Summary Judgment. Good cause also exists because JS for Extension of Time and PO; 2:17-cv-00439-CMK 1 1 Defendant is expected to be on leave for the Thanksgiving holiday. Defendant makes this 2 request in good faith with no intention to unduly delay the proceedings. The parties further 3 stipulate that the Court’s Scheduling Order shall be modified accordingly. 4 5 Respectfully submitted, 6 7 Dated: November 20, 2017 /s/ *Monica Perales (*as authorized by email on November 17, 2017) MONICA PERALES Attorney for Plaintiff Dated: November 20, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 8 9 10 11 12 13 14 By 15 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant 16 17 ORDER 18 19 APPROVED AND SO ORDERED: 20 21 22 Dated: November 28, 2017 23 24 25 26 27 28 JS for Extension of Time and PO; 2:17-cv-00439-CMK 2

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