Bailey v. Commissioner of Social Security

Filing 27

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 09/19/18. DEEMING the 26 Cross-Motion for Summary Judgment timely. (Benson, A.)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
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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JOSEF BAILEY,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-02360-JAM-DMC
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME FOR
DEFENDANT’S RESPONSE TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time to respond to Plaintiff’s motion

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for summary judgment, to the new due date of September 18, 2018.

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There is good cause for this request. Since the Court’s granting of Defendant’s previous

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request for a brief extension of time of 5 days, Defendant’s counsel has been addressing her full

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workload of district court cases and other cases since returning from approved leave for multiple

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weeks. In addition, new matters that were not previously anticipated, had arisen and have

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created some crowding of the briefing schedule around the due date of this case. Thus,

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Defendant is respectfully requesting additional time up to and including September 18, 2018, to

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fully review the record and research the issues presented by Plaintiff’s motion for summary

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judgment in this case. This request is made in good faith with no intention to unduly delay the

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proceedings.

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Respectfully submitted,
Date: September 17, 2018
s/ Jesse S. Kaplan by C.Chen*
(As authorized by email on 9/17/2018)
JESSE S. KAPLAN
Attorneys for Plaintiff

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Date: September 17, 2018

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MCGREGOR W. SCOTT
United States Attorney

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By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED. DEFENDANT’S CROSS-MOTION, FILED ON
SEPTEMBER 17, 2018, IS DEEMED TIMELY.

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Dated: September 19, 2018
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DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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