Foster v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 12/21/2017 EXTENDING time until 1/22/2018, for Defendant to file her Cross-Motion for Summary Judgment and Opposition to 13 Motion. (York, M)

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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: 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 December 22, 2017 to January 22, 2018. This is Defendant’s second request for 23 extension. Good cause exists to grant Defendant’s request for extension. Additional time is 24 required as Counsel for Defendant has over 60 active pending matters, of which require 2+ 25 responses to dispositive motions per week until mid-January. In addition, Counsel has three 26 pending Ninth Circuit matters due in early January which require additional levels of review. 27 Due to current workload demands and shortened staff, Counsel needs additional time to 28 adequately review the transcript and properly respond to Plaintiff’s Motion for Summary JS for Extension of Time and PO; 2:17-cv-00439-CMK 1 1 Judgment. Good cause also exists because Defendant is expected to be on leave from December 2 22, 2017 through December 27, 2017, which falls on the current filing deadline. Defendant 3 makes this request in good faith with no intention to unduly delay the proceedings. The parties 4 further stipulate that the Court’s Scheduling Order shall be modified accordingly. 5 6 Respectfully submitted, 7 8 Dated: December 12, 2017 /s/ *Monica Perales (*as authorized by email on December 12, 2017) MONICA PERALES Attorney for Plaintiff Dated: December 12, 2017 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 9 10 11 12 13 14 15 By 16 17 18 ORDER 19 20 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant APPROVED AND SO ORDERED: 21 22 Dated: December 21, 2017 23 24 25 26 27 28 JS for Extension of Time and PO; 2:17-cv-00439-CMK 2

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