Abdullah v. Commissioner of Social Security

Filing 18

ORDER signed by Magistrate Judge Dennis M. Cota on 3/20/2019 EXTENDING Time to 4/8/2019, for Defendant to file its Cross-Motion for Summary Judgment and Opposition to 16 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
CHANTAL R. JENKINS, PA SBN 307531
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
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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MOHDMAHIR BIN ABDULLAH,
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Plaintiff,
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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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) 2:17-cv-02522-DMC
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) MOTION AND PROPOSED ORDER FOR
) AN EXTENSION OF TIME
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Defendant hereby moves for a three-week extension of time from March 18, 2019 to

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April 8, 2019 respond to Plaintiff’s opening brief. Defendant’s counsel unexpectedly had to

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leave work last week for two days to travel out of state for a family member’s funeral.

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Defendant’s counsel has to complete four briefs in other social security cases and represent the

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agency in an oral argument within the next month. Defendant’s counsel also has to assist the

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U.S. Attorney’s Office in responding to a complaint in a federal court employment case where

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the answer is due in three weeks.

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Defendant’s counsel contacted Plaintiff via phone on March 14 and March 15, but has
not heard back from Plaintiff.

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This request is made in good faith with no intention to unduly delay the proceedings.

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Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: March 18, 2019

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/ Chantal R. Jenkins
CHANTAL R. JENKINS
Special Assistant United States Attorney

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ORDER
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APPROVED AND SO ORDERED NUNC PRO TUNC TO MARCH 18, 2019:
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Dated:

March 20, 2019
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DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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