Blackwell v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER FOR AN EXTENSION OF TIME signed by Magistrate Judge Carolyn K. Delaney on 4/24/18. The New date for Defendant's response to Plaintiff's Motion for Summary Judgment is 5/1/2018. The parties are advised that, absent extraordinary cause, no further extensions of time will be granted. (Mena-Sanchez, L)

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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 ORDER FOR AN
EXTENSION OF TIME OF 7 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 7 additional days to respond

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to Plaintiff’s motion for summary judgment. The current due date is April 24, 2018. The new

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due date will be May 1, 2018.

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There is good cause for this request. Since the court’s granting of Defendant’s previous

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request for an extension of time to file Defendant’s response to Plaintiff’s motion for summary

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

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assigned additional and unanticipated matters that had immediate deadlines and could not be

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assigned to another attorney, including filing an appeal to a recently received decision from the

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California Unemployment Insurance Appeals Board. Furthermore, the weekend of March 30,

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2018, Defendant’s counsel had a serious personal emergency and took multiple days of leave to

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address and recover from the emergency. Defendant’s counsel is addressing the backlog of cases

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that she could not address while on leave.

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Thus, Defendant is respectfully requesting additional time up to and including May 1,

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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: April 23, 2018

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s/ Monica Perales by C.Chen*
(As authorized by email on 4/23/2018)
MONICA PERALES
Attorneys for Plaintiff

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MONICA PERALES, LAW OFFICES OF
LAWRENCE D. ROHLFING

Date: April 23, 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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The parties are advised that, absent extraordinary cause, no further extensions of time will be
granted.

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Dated: April 24, 2018

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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