Miranda v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 6/15/18 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED from 6/14/18 to 7/16/18. (Becknal, R)
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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 268-5611
Facsimile: (415) 744-0134
E-Mail: Tina.Naicker@SSA.gov
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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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ERIC GONZALES MIRANDA,
Plaintiff,
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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
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Defendant.
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Case No.: 2:17-cv-01653-CMK
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT
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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from June
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14, 2018 to July 16, 2018. This is Defendant’s first request for extension. Good cause exists to
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grant Defendant’s request for extension. Counsel respectfully requests additional time to
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respond to Plaintiff’s Motion for Summary Judgment due to shortened staff, unexpected leave
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and heavy workload. Counsel has over 75+ pending social security cases, which require two or
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more dispositive motions a week until July. Defendant makes this request in good faith with no
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intention to unduly delay the proceedings.
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Joint Stipulation and PO for Extension of Time
Case No. 2:17-cv-01653-CMK
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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Respectfully submitted,
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Dated: June 13, 2018
s/ *Jacqueline Forslund
(*as authorized by email on June 9, 2018)
JACQUELINE FORSLUND
Attorney for Plaintiff
Dated: June 13, 2018
MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
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By
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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
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ORDER
APPROVED AND SO ORDERED:
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Dated: June 15, 2018
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Joint Stipulation and PO for Extension of Time
Case No. 2:17-cv-01653-CMK
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