Edmon v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 11/20/2017 EXTENDING time until 12/17/2017, for defendant to respond to plaintiff's 18 Motion for Summary Judgment. (York, M)

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

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Case No.: 2:17-cv-00447-EFB
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME FOR DEFENDANT 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 17, 2017 to December 17, 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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(Counsel) was on intermittent medical leave due to a recent hand injury and for chronic

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migraines. As a result of Counsel’s unanticipated medical leave, Counsel became behind on her

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caseload. Counsel currently has an active caseload of over 70 pending active social security

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matters that require two or more dispositive motions a week until mid-December. In addition,

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Counsel has a Ninth Circuit brief due on or around December 12, 2017. Due to shortened staff

JS for Extension of Time; 2:17-cv-00447-EFB

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and high workload demands, Defendant respectfully requests additional time in order to

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adequately assess the issues raised in Plaintiff’s Motion. Counsel apologizes for the belated

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nature of the request, but did not anticipate taking additional medical leave. Defendant makes

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this 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 14, 2017

/s/ *Bess M. Brewer
(*as authorized by email on November 8, 2017)
BESS M. BREWER
Attorney for Plaintiff

Dated: November 14, 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
APPROVED AND SO ORDERED.
DATED: November 20, 2017.

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JS for Extension of Time; 2:17-cv-00447-EFB

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