Bell v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 01/24/18 ORDERING that Defendant's date to respond to Plaintiff's motion for summary judgment is EXTENDED to 02/21/18. (Benson, A.)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
Chantal R. Jenkins, SBN PA 307531
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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CHARLES HENRY BELL,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-01195-KJN
STIPULATION & ORDER FOR
EXTENSION FOR DEFENDANT TO
RESPOND 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 30 days to respond to

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Plaintiff’s motion for summary judgment. The current due date is January 22, 2018. The new

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due date will be February 21, 2018.

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Defendant respectfully requests this additional time because Defendant’s counsel is

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managing a heavy caseload. Since Plaintiff’s counsel filed her motion for summary judgment,

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Defendant’s counsel has been engaged in discovery in two cases before the Equal Employment

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Opportunity Commission (EEOC). In addition, counsel has several district court briefs for social

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security disability cases and an oral argument this month.

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Defendant’s counsel contacted Plaintiff’s counsel via telephone on January 19th and
Plaintiff’s counsel has agreed to the extension request.

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This request is made in good faith with no intention to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified

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accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: January 18, 2018

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/s/ Steven Berniker by Chantal R. Jenkins*
*As authorized via email on January 19,
2018
Steven Berniker
Attorney for Plaintiff

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Respectfully submitted,

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MCGREGOR W. SCOTT
United States Attorney

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Dated: January 18, 2018

/s/ Chantal R. Jenkins
Chantal R. Jenkins
Special Assistant United States Attorney

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: January 24, 2018

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