Baugh v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 12/4/2017 EXTENDING Time until 1/12/2018, for Defendant to Respond to 10 Motion for Summary Judgment. (York, M)

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1 2 3 4 5 6 7 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: (415) 977-8929 Facsimile: (415) 744-0134 E-Mail: Margaret.Branick-Abilla@ssa.gov 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 ALEXANDRIA BAUGH, 14 15 Plaintiff, vs. 16 17 NANCY A. BERRYHILL, Acting Commissioner of Social Security, 18 Defendant. 19 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-01382-AC STIPULATION & [PROPOSED] ORDER FOR EXTENSION OF TIME 20 21 22 23 24 25 26 27 28 IT IS HEREBY STIPULATED, by and between the parties through their respective counsel of record, that Defendant shall have a 35-day extension of time, from December 8, 2017, to January 12, 2018, for Defendant to respond to Plaintiff’s Motion for Summary Judgment. All other dates in the Court’s Scheduling Order shall be extended accordingly. This is Defendant’s first request for an extension of time. Defendant respectfully submits that good cause exists for the requested extension because Defendant’s counsel requires additional time to review the record, to evaluate the issues raised in Plaintiff’s Motion for Summary Judgment, to determine whether options exist for settlement, to prepare Defendant’s Stipulation & PO; Case No.: 2:17-cv-01382-AC 1 1 response to Plaintiff’s Motion if settlement is not possible, and to accommodate competing 2 workloads. This request is made in good faith with no intention to unduly delay the proceedings. 3 Plaintiff does not oppose the requested extension. 4 Respectfully submitted, 5 6 Dated: December 1, 2017 LAW OFFICE OF NANCY MCCOMBS 7 By: /s/ Nancy K. McCombs* NANCY K. MCCOMBS Attorneys for Plaintiff [*As authorized by e-mail on Dec. 1, 2017] 8 9 10 11 12 Dated: December 4, 2017 13 14 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 15 16 By: /s/ Margaret Branick-Abilla ___ MARGARET BRANICK-ABILLA Special Assistant United States Attorney Attorneys for Defendant 17 18 19 [PROPOSED] ORDER 20 21 22 Pursuant to stipulation, IT IS SO ORDERED. 23 24 Dated: December 4, 2017 25 26 27 28 Stipulation & PO; Case No.: 2:17-cv-01382-AC 2

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