Stevens v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 7/11/18 ORDERING that the time for defendant to respond to Plaintiff's Motion for Summary Judgment is EXTENDED from 7/3/18 to 8/3/18. (Becknal, R)

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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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
14
15
16
17

JAMES STEVENS,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

18
19

)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 2:17-cv-02496-CMK
JOINT STIPULATION AND ORDER
FOR EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

20

that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from July

21

3, 2018 to August 3, 2018. This is Defendant’s first request for extension. Good cause exists to

22

grant Defendant’s request for extension. Counsel had a death of a family member and is

23

attending prayer services in the next few weeks. In addition, Counsel has over 85+ pending

24

social security cases, which require two or more dispositive motions a week until August. Due to

25

current workload demands and upcoming leave, Counsel needs additional time to adequately

26

review the transcript and properly respond to Plaintiff’s Motion for Summary Judgment.

27

Defendant makes this request in good faith with no intention to unduly delay the proceedings.

28

Counsel apologizes for the belated request, but did not anticipate being out on the current filing
JS for Extension of Time

Case No. 2:17-cv-02496-CMK

1

1

deadline due to the unexpected death of a family member. The parties further stipulate that the

2

Court’s Scheduling Order shall be modified accordingly.

3
4

Respectfully submitted,

5
6

Dated: June 27, 2018

/s/ *Josephine M. Gerrard
(*as authorized by email on June 27, 2018)
JOSEPHINE M. GERRARD
Attorney for Plaintiff

Dated: June 27, 2018

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

7
8
9
10
11
12
13
By

14
15
16
17
18

/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

APPROVED AND SO ORDERED:

19
20
21

Dated: July 11, 2018

22
23
24
25
26
27
28
JS for Extension of Time

Case No. 2:17-cv-02496-CMK

2