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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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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DIMITRIUS FOSTER,

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Plaintiff,

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

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Case No.: 2:17-cv-00439-CMK
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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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 for thirty

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days from November 22, 2017 to December 22, 2017. This is Defendant’s first request for

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extension. Good cause exists to grant Defendant’s request for extension. Counsel for Defendant

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was on unexpected medical leave and became behind on her caseload. Additional time is

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required as Counsel for Defendant has over 75 active pending matters, of which require 2+

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responses to dispositive motions per week until early-January. Due to current workload demands

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and shortened staff, Counsel needs additional time to adequately review the transcript and

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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

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Defendant is expected to be on leave for the Thanksgiving holiday. Defendant makes this

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request in good faith with no intention to unduly delay the proceedings. The parties further

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

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Respectfully submitted,

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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

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated:

November 28, 2017

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JS for Extension of Time and PO; 2:17-cv-00439-CMK

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