Rumantsev v. Commissioner of Social Security
Filing
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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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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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VYACHESLAV RUMANTSEV,
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-02539-EFB
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME FOR DEFENDANT TO
RESPOND TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT
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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that
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the time for responding to Plaintiff’s Motion for Summary Judgment be extended from August
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17, 2018 to August 31, 2018. This is Defendant’s second request for extension. Good cause
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exists to grant Defendant’s request for extension. Counsel had another death in her family this
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week and is out on the current filing deadline. Counsel for Defendant also anticipates taking
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additional leave next week for funeral services. In addition, Counsel has over 85+ pending
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social security cases, which require two or more dispositive motions a week until mid-
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September. Due to current workload demands and upcoming leave, Counsel needs additional
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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
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Judgment. Defendant makes this request in good faith with no intention to unduly delay the
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proceedings. Counsel apologizes for the belated request, but did not anticipate being out on the
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current filing deadline due to the unexpected death of another family member. The parties
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further stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Respectfully submitted,
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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
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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 20, 2018.
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JS for Extension of Time; 2:17-cv-02539-EFB
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