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)

Download PDF
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 14 15 16 17 WANDA EDMON, Plaintiff, vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) 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 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 17, 2017 to December 17, 2017. This is Defendant’s first request for 23 extension. Good cause exists to grant Defendant’s request for extension. Counsel for Defendant 24 (Counsel) was on intermittent medical leave due to a recent hand injury and for chronic 25 migraines. As a result of Counsel’s unanticipated medical leave, Counsel became behind on her 26 caseload. Counsel currently has an active caseload of over 70 pending active social security 27 matters that require two or more dispositive motions a week until mid-December. In addition, 28 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 1 1 and high workload demands, Defendant respectfully requests additional time in order to 2 adequately assess the issues raised in Plaintiff’s Motion. Counsel apologizes for the belated 3 nature of the request, but did not anticipate taking additional medical leave. Defendant makes 4 this request in good faith with no intention to unduly delay the proceedings. The parties further 5 stipulate that the Court’s Scheduling Order shall be modified accordingly. 6 7 Respectfully submitted, 8 9 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 10 11 12 13 14 15 16 By 17 18 19 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant 20 21 22 23 ORDER APPROVED AND SO ORDERED. DATED: November 20, 2017. 24 25 26 27 28 JS for Extension of Time; 2:17-cv-00447-EFB 2

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?