Morales v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 6/28/2018 ORDERING that the Defendant shall have an 8 day extension of time to respond to Plaintiff's MSJ; Filing due 7/6/2018. All other dates in the Court's Scheduling Order shall be EXTENDED accordingly. (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 & [PROPOSED] ORDER
FOR EXTENSION OF TIME
(SECOND REQUEST)

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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 an 8-day extension of
time, from June 28, 2018 to July 6, 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 second request for an extension of time. Defendant respectfully
submits that good cause exists for a second short extension because Defendant’s counsel was out
of the office unexpectedly and requires additional time to complete her review of the record and
analysis of the issues raised in Plaintiff’s Motion for Summary Judgment and to prepare
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Stipulation & PO
2:17-cv-02246-CKD

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Defendant’s response. Defendant’s counsel also has a number of other briefs due and is trying

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diligently to manage competing workload demands. Plaintiff does not oppose Defendant’s

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request for an extension of time.

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Respectfully submitted,

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Dated: June 27, 2018

CERNEY KREUZE & LOTT, LLP

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By: /s/ Shellie Lott*
SHELLIE LOTT
Attorneys for Plaintiff
[*As authorized by e-mail on June 27, 2018]

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Dated: June 28, 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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[PROPOSED] ORDER

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Pursuant to stipulation, IT IS SO ORDERED.
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Dated: June 28, 2018

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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