Edmon v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 12/18/17 ORDERING that the time for defendant to respond to the Motion for Summary Judgment is EXTENDED to 12/22/17. (Benson, A.)

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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 five

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days from December 17, 2017 to December 22, 2017. This is Defendant’s second 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 out on sick leave with the cold/flu. As a result of Counsel’s unanticipated

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medical leave, Counsel became behind on her caseload. Counsel currently has an active

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caseload of over 70 pending active social security matters that require two or more dispositive

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motions a week until mid-January. Due to shortened staff and high workload demands,

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Defendant respectfully requests additional time in order to adequately assess the issues raised in

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

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Plaintiff’s Motion. Counsel apologizes for the belated nature of the request, but did not

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anticipate taking additional medical leave. Defendant makes this request in good faith with no

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intention to unduly delay the proceedings. The parties further stipulate that the Court’s

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Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: December 13, 2017

/s/ *Bess M. Brewer
(*as authorized by email on December 13, 2017)
BESS M. BREWER
Attorney for Plaintiff

Dated: December 13, 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

ORDER
APPROVED AND SO ORDERED.
DATED: December 18, 2017.

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

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