Blackwell v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 3/22/2018 EXTENDING Time up to and including 4/24/2018, for Defendant to File a Response to 15 Motion for Summary Judgment. (York, M)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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ALEXIS DENISE BLACKWELL,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-01599-CKD
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME OF 35
DAYS FOR DEFENDANT’S RESPONSE 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 35 additional days to

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respond to Plaintiff’s motion for summary judgment. The current due date is March 20, 2018.

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The new due date will be April 24, 2018.

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There is good cause for this request. Since the filing of Plaintiff’s motion for summary

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judgment, Defendant’s counsel has been diligently addressing her full workload including

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several district court cases and one Equal Employment Opportunity Commission matter

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involving briefing. Moreover, recently, Defendant’s counsel was assigned unanticipated work,

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including an additional employment law matter involving the appeal of a recently received

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decision, with the appeal due around the same time as the original due date of Defendant’s

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response in this case, that could not be assigned to another attorney and that could not be

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extended. Defendant’s counsel continues to have a full workload of district court cases and

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employment law cases in the next month.

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Thus, Defendant is respectfully requesting additional time up to and including April 24,

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2018, to fully review the record and research the issues presented by Plaintiff’s motion for

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summary judgment in this case. This request is made in good faith with no intention to unduly

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delay the proceedings.

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Respectfully submitted,
Date: March 20, 2018

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s/ Monica Perales by C.Chen*
(As authorized by email on 3/20/2018)
MONICA PERALES
Attorneys for Plaintiff

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MONICA PERALES, LAW OFFICES OF
LAWRENCE D. ROHLFING

Date: March 20, 2018

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MCGREGOR W. SCOTT
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated: March 22, 2018

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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