Alam v. Commissioner of Social Security

Filing 24

ORDER signed by Magistrate Judge Craig M. Kellison on 1/16/2018 ORDERING that Defendant's time to file her summary judgment motion with the Court by 14 days to 1/24/2018, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. (Reader, L)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI, NYSBN 4692018
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
Email: [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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RUBINA ZAFAR ALAM,

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Plaintiff,

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v.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

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) Case No.: 2:17-cv-0701-JAM-CMK
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) STIPULATION AND ORDER TO
) EXTEND BRIEFING SCHEDULE
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to
extend Defendant’s time to file her summary judgment motion with the Court by 14 days to
January 24, 2018, and that all other scheduling dates set forth in the Court’s Case Management
Order shall be extended accordingly. This is Defendant’s first request for an extension of time in
this matter and she requests it in good faith and without any intent to prolong proceedings
unduly.
There is good cause for this extension request because counsel for Defendant has
workload issues that preclude filing the summary judgment motion by January 10, 2018. In
particular, counsel for Defendant is currently responsible for performing an extensive range of

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tasks, including: reviewing the excerpts of record and drafting the Commissioner’s answering

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brief in a Social Security case before the Ninth Circuit; preparing for an oral argument before the

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Ninth Circuit in a Social Security case; drafting briefs and summary judgment motions and

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negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act before

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the district courts within the Ninth Circuit; conducting discovery in personnel-related litigation

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pending before the Equal Employment Opportunity Commission; preparing for an arbitration

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proceeding involving the agency and one of the agency’s collective bargaining units; and

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assisting with implementing the terms of the class action settlement reached in Hart v. Berryhill

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(N.D.Cal. No. 3:15-cv-623-JST). Furthermore, due to recent holiday and work-related absences

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from the office, counsel for Defendant requires this short-term extension to fully evaluate the

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factual and legal issues presented in Plaintiff’s summary judgment motion.

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Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused
by this delay.
Respectfully submitted,

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Date: January 9, 2018

CERNEY KREUZE & LOTT, LLP
By:

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Date: January 9, 2018

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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/s/ Asim H. Modi for Langley Kreuze*
LANGLEY KREUZE
*Authorized by email on January 9, 2018
Attorney for Plaintiff

By:

/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED

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Dated: January 16, 2018

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