Stevens v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 9/19/2018 ORDERING that the time for responding to plaintiff's motion for summary judgment is EXTENDED to 9/19/2018. (Washington, S)

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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: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov 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 JAMES STEVENS, Plaintiff, 14 15 16 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, 17 Defendant. 18 19 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-02496-DMC 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 21 September 18, 2018 to September 19, 2018. This is Defendant’s fourth request for extension. 22 Good cause exists to grant Defendant’s request for extension. Counsel went to urgent care for a 23 medical emergency on the date of the current filing deadline and was not able to finish 24 Defendant’s response. Defendant makes this request in good faith with no intention to unduly 25 delay the proceedings. Counsel apologizes for the belated request, but made the request as soon 26 as practicable. 27 28 JS for Extension of Time Case No. 2:17-cv-02496-DMC 1 1 2 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 3 Respectfully submitted, 4 5 Dated: September 18, 2018 /s/ *Josephine M. Gerrard (*as authorized by email on September 18, 2018) JOSEPHINE M. GERRARD Attorney for Plaintiff Dated: September 18, 2018 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 6 7 8 9 10 11 12 By 13 14 15 16 17 18 19 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant ORDER APPROVED AND SO ORDERED. FURTHER REQUESTS FOR EXTENSIONS OF TIME TO FILE A PARTY’S BRIEF SUBMITTED ON THE EVE OF THE DEADLINE WILL BE DISFAVORED UNLESS THE BRIEF IS FILED WITH THE REQUEST. 20 21 22 Dated: September 19, 2018 ____________________________________ DENNIS M. COTA UNITED STATES MAGISTRATE JUDGE 23 24 25 26 27 28 JS for Extension of Time Case No. 2:17-cv-02496-DMC 2

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