Kreis v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 5/15/18 ORDERING that Defendant shall have an extension of time of 14 additional days to respond to Plaintiffs Motion for Summary Judgment. The new due date will be 5/29/2018. (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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TONI KREIS,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-01633-JAM-CMK
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME OF 14 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 14 additional days to

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respond to Plaintiff’s motion for summary judgment. The current due date is May 14, 2018. The

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new due date will be May 29, 2018 (May 28, 2018 is a federal holiday).

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This is Defendant’s first request for an extension of time in this case. There is good

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cause for this request. During the weekend of April 1, 2018, Defendant’s counsel had a serious

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personal emergency and took multiple days of leave to address and recover from the emergency

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and continues to take leave intermittently for treatment. Defendant’s counsel is continuing to

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address and prioritize the backlog of cases that she could not address while on leave.

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Thus, Defendant is respectfully requesting additional time up to and including May 29,

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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: May 11, 2018

CERNEY KREUZE & LOTT, LLP

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s/ Shellie Lott by C.Chen*
(As authorized by email on 5/11/2018)
SHELLIE LOTT
Attorneys for Plaintiff

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Date: May 11, 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
APPROVED AND SO ORDERED:

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Dated: May 15, 2018

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