Morales v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/11/2018 GRANTING a 45 day extension of time for Defendant to respond to Plaintiff's Motion for Summary Judgment; Response due 6/28/2018. (Fabillaran, J)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
MARGARET BRANICK-ABILLA, CSBN 223600
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
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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VICTORIA MORALES,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

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Case No. 2:17-cv-02246-CKD
STIPULATION & ORDER FOR
EXTENSION OF TIME

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IT IS HEREBY STIPULATED, by and between the parties through their respective
counsel of record, with the Court’s approval, that Defendant shall have a 45-day extension of
time, from May 14, 2018 to June 28, 2018, to respond to Plaintiff’s Motion for Summary
Judgment. All other dates in the Court’s Scheduling Order shall be extended accordingly.
This is Defendant’s first request for an extension of time. Defendant respectfully submits
that good cause exists for the requested extension because Defendant’s counsel requires
additional time to review the record, to evaluate the issues raised in Plaintiff’s Motion for
Summary Judgment, to determine whether options exist for settlement, to prepare Defendant’s

Stipulation & PO
2:17-cv-02246-CKD

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response to Plaintiff’s Motion if settlement is not possible, and to accommodate other workload

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demands. Plaintiff does not oppose Defendant’s request for an extension of time.

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Respectfully submitted,

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Dated: May 9, 2018

CERNEY KREUZE & LOTT, LLP

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By: /s/ Shellie Lott*
SHELLIE LOTT
Attorneys for Plaintiff
[*As authorized by e-mail on May 9, 2018]

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Dated: May 11, 2018

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By: /s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.
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Dated: May 11, 2018

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stipulation & PO
2:17-cv-02246-CKD