Stevens v. Commissioner of Social Security
Filing
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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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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
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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,
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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
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Defendant.
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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,
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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from
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September 18, 2018 to September 19, 2018. This is Defendant’s fourth request for extension.
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Good cause exists to grant Defendant’s request for extension. Counsel went to urgent care for a
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medical emergency on the date of the current filing deadline and was not able to finish
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Defendant’s response. Defendant makes this request in good faith with no intention to unduly
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delay the proceedings. Counsel apologizes for the belated request, but made the request as soon
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as practicable.
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JS for Extension of Time
Case No. 2:17-cv-02496-DMC
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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Respectfully submitted,
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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
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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. 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.
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Dated: September 19, 2018
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DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE
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JS for Extension of Time
Case No. 2:17-cv-02496-DMC
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