Miranda v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 7/11/18, ORDERING that defendant is GRANTED an extension of time until 8/13/18 to respond to plaintiff's motion for summary judgment. (Kastilahn, A)

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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
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 July

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13, 2018 to August 13, 2018. This is Defendant’s second request for extension. Good cause

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exists to grant Defendant’s request for extension. Counsel had a death of a family member and is

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attending prayer services in the next few weeks. In addition, Counsel has over 85+ pending

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social security cases, which require two or more dispositive motions a week until mid-August.

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Due to current workload demands and upcoming leave, Counsel needs additional time to

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adequately review the transcript and properly respond to Plaintiff’s Motion for Summary

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Judgment. Defendant makes this request in good faith with no intention to unduly delay the
Joint Stipulation and PO for Extension of Time

Case No. 2:17-cv-01653-CMK

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proceedings. Counsel apologizes for the belated request, but did not anticipate being out on the

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current filing deadline due to the unexpected death of a family member. The parties further

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stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: July 5, 2018

s/ *Jacqueline Forslund
(*as authorized by email on July 3, 2018)
JACQUELINE FORSLUND
Attorney for Plaintiff

Dated: July 5, 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:

July 11, 2018

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Joint Stipulation and PO for Extension of Time

Case No. 2:17-cv-01653-CMK

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