Coleman v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 2/13/2018 GRANTING an Extension of Time for defendant to file summary judgment motion to 3/23/2018. (Hunt, G)

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1 2 3 4 5 6 7 8 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: 415-977-8952 Facsimile: 415-744-0134 Email: Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 KHATARI COLEMAN, 14 Plaintiff, 15 v. 16 17 NANCY A. BERRYHILL, Acting Commissioner of Social Security, 18 Defendant. 19 20 21 22 23 24 25 26 27 28 ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-1069-EFB STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE 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 30 days to March 23, 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 February 21, 2018. In particular, counsel for Defendant is currently responsible for performing an extensive range of -1- 1 tasks, including: reviewing the excerpts of record and drafting the Commissioner’s answering 2 brief in a Social Security case before the Ninth Circuit; drafting briefs and summary judgment 3 motions and negotiating (or litigating) attorney fee matters pursuant to the Equal Access to 4 Justice Act before the district courts within the Ninth Circuit; preparing for a hearing in 5 personnel-related litigation pending before the Equal Employment Opportunity Commission 6 (EEOC); completing discovery in personnel-related litigation pending before the EEOC; 7 preparing for an arbitration proceeding involving the agency and one of the agency’s collective 8 bargaining units; and assisting with implementing the terms of the class action settlement 9 reached in Hart v. Berryhill (N.D. Cal. No. 3:15-cv-623-JST). 10 11 Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay. 12 Respectfully submitted, 13 14 Date: February 13, 2018 BAY AREA LEGAL AID By: 15 16 17 18 Date: February 13, 2018 /s/ Asim H. Modi for Donald Medearis* DONALD MEDEARIS *Authorized by email on February 13, 2018 Attorney for Plaintiff MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 19 20 21 By: 22 23 /s/ Asim H. Modi ASIM H. MODI Special Assistant United States Attorney Attorneys for Defendant 24 ORDER 25 26 27 APPROVED AND SO ORDERED. DATED: February 13, 2018. 28 -2-

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