Stevens v. Commissioner of Social Security

Filing 16

SECOND STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 8/3/2018 EXTENDING Time through 9/5/2018, for Defendant to file its Cross-Motion for Summary Judgment. (York, M)

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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]

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

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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,

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

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August 3, 2018 to September 5, 2018. This is Defendant’s second request for extension. Good

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cause exists to grant Defendant’s request for extension. Since the date of the Counsel’s last

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request for extension, Counsel had another second sudden death in her extended family. In

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addition, Counsel has over 85+ pending social security cases, which require two or more

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dispositive motions a week until late September. Counsel was also out previously due to

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ongoing medical issues. Due to current workload demands and unanticipated bereavement and

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medical leave, Counsel needs additional time to adequately review the transcript and properly

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respond to Plaintiff’s Motion for Summary Judgment. Defendant makes this request in good
JS for Extension of Time

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

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faith with no intention to unduly delay the proceedings. Counsel apologizes for the belated

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request, but did not anticipate being out on the current filing deadline due to the second

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unexpected death in her extended family. The parties further stipulate that the Court’s

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Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: August 2, 2018

/s/ *Josephine M. Gerrard
(*as authorized by email on August 2, 2018)
JOSEPHINE M. GERRARD
Attorney for Plaintiff

Dated: August 2, 2018

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

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By

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

APPROVED AND SO ORDERED:

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Dated: August 3, 2018

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JS for Extension of Time

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

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