Ramos v. Commisioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 12/21/17 ORDERING that the time for Defendant to file her Opposition to Plaintiff's Motion for Summary Judgment is EXTENDED to 01/03/18. (Benson, A.)

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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]
Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARISELA RAMOS,
Plaintiff,
vs.
NANCY A. BERRYHILL
Acting Commissioner of Social Security,
Defendant.

) Case No.: 2:17-cv-01007-CMK
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) JOINT STUPULATION AND ORDER
) FOR EXTENSION OF TIME
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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 December 20, 2017, by 14 days,

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through and including January 3, 2018. This is the Commissioner’s second request for an

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extension of time in this matter.

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Good cause exists to grant a brief extension in this matter for Defendant to file her

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opposition because of counsel’s workload in the weeks prior to the holidays, including a major

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EEOC discovery production, four district court summary judgment motions due last week, and a

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major EEOC summary adjudication motion due next week, in addition to the brief in the present
matter. This request is made in good faith with no intention to unduly delay the proceedings.
Stipulation for Extension of Time; 2:17-cv-01007-CMK 1

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Counsel’s office conferred with Plaintiff’s counsel, who had no objection to this request, on

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December 14, 2017.

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Respectfully submitted,
Dated: December 19, 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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Dated: December 19, 2017

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By:

/s/ Lawrence Rohlfing*
LAWRENCE ROHLFING
(*by email authorization)
Attorney for Plaintiff

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ORDER

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IT IS SO ORDERED.

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Dated: December 21, 2017

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Stipulation for Extension of Time; 2:17-cv-01007-CMK 2