Rumantsev v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 8/20/18: The time for responding to Plaintiff's Motion for Summary Judgment shall be extended from August 17, 2018 to August 31, 2018. (Kaminski, H)

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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 14 VYACHESLAV RUMANTSEV, Plaintiff, 16 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security 17 Defendant. 15 18 ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:17-cv-02539-EFB JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that 21 the time for responding to Plaintiff’s Motion for Summary Judgment be extended from August 22 17, 2018 to August 31, 2018. This is Defendant’s second request for extension. Good cause 23 exists to grant Defendant’s request for extension. Counsel had another death in her family this 24 week and is out on the current filing deadline. Counsel for Defendant also anticipates taking 25 additional leave next week for funeral services. In addition, Counsel has over 85+ pending 26 social security cases, which require two or more dispositive motions a week until mid- 27 September. Due to current workload demands and upcoming leave, Counsel needs additional 28 time to adequately review the transcript and properly respond to Plaintiff’s Motion for Summary JS for Extension of Time; 2:17-cv-02539-EFB 1 1 Judgment. Defendant makes this request in good faith with no intention to unduly delay the 2 proceedings. Counsel apologizes for the belated request, but did not anticipate being out on the 3 current filing deadline due to the unexpected death of another family member. The parties 4 further stipulate that the Court’s Scheduling Order shall be modified accordingly. 5 6 Respectfully submitted, 7 8 Dated: August 17, 2018 /s/ *Jesse Kaplan (*as authorized by email on August 17, 2018) JESSE KAPLAN Attorney for Plaintiff Dated: August 17, 2018 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 9 10 11 12 13 14 15 By 16 17 18 19 20 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant ORDER APPROVED AND SO ORDERED. 21 22 DATED: August 20, 2018. 23 24 25 26 27 28 JS for Extension of Time; 2:17-cv-02539-EFB 2

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