Kadhum v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 11/14/17, ORDERING that defendant has until 11/29/2017 to respond to plaintiff's motion for summary judgment. (Kastilahn, A)

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
MARGARET BRANICK-ABILLA, CSBN 223600
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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SACRAMENTO DIVISION
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ANAAM KADHUM,

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Plaintiff,
vs.

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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-00815-CKD
STIPULATION & ORDER FOR
EXTENSION OF TIME (SECOND
REQUEST)

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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 a 14-day extension of time, from November 15,

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2017, to November 29, 2017, for Defendant to respond to Plaintiff’s Motion for Summary

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Judgment. All other dates in the Court’s Scheduling Order shall be extended accordingly.

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This is Defendant’s second request for an extension of time. Defendant respectfully

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submits that good cause exists for the requested extension because Defendant’s counsel has been

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out sick and requires additional time to review the record, to evaluate the issues raised in

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Plaintiff’s Motion for Summary Judgment, to determine whether options exist for settlement, and

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if not, to prepare Defendant’s response to Plaintiff’s Motion. This request is made in good faith

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with no intention to unduly delay the proceedings, and counsel apologizes for any

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inconvenience. Plaintiff does not oppose the requested extension.

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Respectfully submitted,

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Dated: November 13, 2017

JACQUELINE A. FORSLUND, ATTORNEY AT LAW

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By: /s/ Jacqueline A. Forslund*
JACQUELINE A. FORSLUND
Attorneys for Plaintiff
[*As authorized by e-mail on Nov. 13, 2017]

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Dated: November 14, 2017

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PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By: /s/ Margaret Branick-Abilla
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MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.

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Dated: November 14, 2017
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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE