Hudson v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 10/12/2017 GRANTING Defendant's Extension of Time to 11/27/2017 to respond to Plaintiff's Motion for Summary Judgment. (Hunt, G)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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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GERALD WILLIAM HUDSON,
Plaintiff,

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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

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Case No.: 2:17-cv-00589-CMK
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 45 DAYS FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time of an additional 45 days to

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respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by

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Defendant. The current due date is October 11, 2017. The new due date will be November 27,

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2017.

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There is good cause for this request. Since the filing of Plaintiff’s motion for summary

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judgment, Defendant’s counsel has been diligently addressing her full workload including

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several district court cases and one Equal Employment Opportunity Commission matter

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involving discovery, depositions, and travel. Moreover, in October, Defendant’s counsel was

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assigned additional unanticipated matters that involved hearing and witness preparation. Despite

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counsel’s diligence in responding to the new matters and her remaining workload, counsel was

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set back in addressing a number of her cases, including this one, and other cases that have been

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extended. Furthermore, Defendant’s counsel will be traveling for work, attending two hearings,

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and conducting additional depositions in the remainder of October and November. She will also

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be addressing other district court cases that have already been extended, previous to this one, due

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to her schedule.

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Therefore, Defendant is respectfully requesting additional time up to and including
November 27, 2017, to fully review the record and research the issues presented by Plaintiff’s

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motion for summary judgment in this case. This request is made in good faith with no intention

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to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.
Respectfully submitted,

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Date: October 11, 2017

LAW OFFICES OF STUART T. BARASCH

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s/ Oscar Gomez for Stuart T. Barasch by C.Chen*
(As authorized by phone on 10/11/2017)
STUART T. BARASCH
Attorneys for Plaintiff

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Date: October 11, 2017

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PHILLIP A. TALBERT
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated: October 12, 2017

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