Barnes v. Commissioner of Social Security

Filing 15

ORDER signed by Magistrate Judge Craig M. Kellison on 9/11/2017 ORDERING that the time for Defendant to file an Opposition to Plaintiff's Motion for Summary Judgment, originally due on 10/2/2017, by 45 days, through and including Thursday, 11/16/2017. (Reader, L)

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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
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
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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SARAH BARNES,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL
Acting Commissioner of Social Security,

) Case No.: 2:17-cv-00458-CMK
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) JOINT STUPULATION AND ORDER
) FOR EXTENSION OF TIME
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Defendant.

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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to

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Plaintiff’s Motion for Summary Judgment, originally due on October 2, 2017, by 45 days,

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through and including Thursday, November 16, 2017. This is the Commissioner’s first request

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for an extension of time in this matter.

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An extension of time is needed in order to prepare Defendant’s opposition because

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counsel will be on his honeymoon for the last three weeks of September and the beginning of

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October, and faces a heavy caseload when he returns. This request is made in good faith with no

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intention to unduly delay the proceedings. Counsel’s office conferred with Plaintiff’s counsel,
who had no objection to this request, on September 8, 2017.
Stipulation for Extension of Time; 2:17-cv-00458-CMK 1

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Respectfully submitted,
Dated: September 8, 2017

PHILIP 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/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney

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Attorneys for Defendant

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/s/ Young Cho*
YOUNG CHO
(*by email authorization)

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Attorney for Plaintiff

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Dated: September 8, 2017

By:

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ORDER

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IT IS SO ORDERED.

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Dated: September 11, 2017

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Stipulation for Extension of Time; 2:17-cv-00458-CMK 2