Pollard v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 4/16/2018 EXTENDING time for Defendant to respond to 16 MSJ; Defendant to file response by 6/01/2018. (Fabillaran, J)

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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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MEJONAH POLLARD,

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Plaintiff,

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vs.
NANCY A. BERRYHILL,
Deputy Commissioner for Operations,
performing the duties and functions not
reserved to the Commissioner of Social
Security,

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Case No.: 2:17-cv-01788-KJN
JOINT STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

Defendant.

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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 April

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26, 2018 to June 1, 2018. This is Defendant’s first request for extension. Good cause exists to

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grant Defendant’s request for extension. Counsel has been on intermittent medical leave due to

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her chronic migraines, which impair her vision. Counsel has over 75+ pending social security

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cases, which require two or more dispositive motions a week until late June. Counsel also has

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two pending Ninth Circuit matters that require additional levels of review and two pending civil
JS for Extension of Time

Case No. 2:17-cv-01788-KJN

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rights matters which require imminent attention and investigation. Due to current workload

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demands and unanticipated leave, Counsel became behind on her heavy caseload and needs

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

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Summary Judgment. Defendant makes this request in good faith with no intention to unduly

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delay the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be

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modified accordingly.

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Respectfully submitted,

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Dated: April 13, 2018

s/ *Jesse Kaplan
(*as authorized by email on April 13, 2018)
JESSE KAPLAN
Attorney for Plaintiff

Dated: April 13, 2018

McGREGOR W. SCOTT
Acting 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: April 16, 2018

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JS for Extension of Time

Case No. 2:17-cv-01788-KJN

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