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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7 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 8 Attorneys for Defendant 1 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 MEJONAH POLLARD, 14 Plaintiff, 15 vs. NANCY A. BERRYHILL, Deputy Commissioner for Operations, performing the duties and functions not reserved to the Commissioner of Social Security, 16 17 18 19 ) ) ) ) ) ) ) ) ) ) ) ) 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. 20 21 22 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, 23 that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from April 24 26, 2018 to June 1, 2018. This is Defendant’s first request for extension. Good cause exists to 25 grant Defendant’s request for extension. Counsel has been on intermittent medical leave due to 26 her chronic migraines, which impair her vision. Counsel has over 75+ pending social security 27 cases, which require two or more dispositive motions a week until late June. Counsel also has 28 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 1 1 rights matters which require imminent attention and investigation. Due to current workload 2 demands and unanticipated leave, Counsel became behind on her heavy caseload and needs 3 additional time to adequately review the transcript and properly respond to Plaintiff’s Motion for 4 Summary Judgment. Defendant makes this request in good faith with no intention to unduly 5 delay the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be 6 modified accordingly. 7 Respectfully submitted, 8 9 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 10 11 12 13 14 15 16 17 By 18 19 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant 20 21 22 ORDER APPROVED AND SO ORDERED: 23 24 Dated: April 16, 2018 25 26 27 28 JS for Extension of Time Case No. 2:17-cv-01788-KJN 2

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