Rumantsev v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 8/31/2018 GRANTING Defendant's extension of time to respond to Plaintiff's Motion for Summary Judgment from August 31, 2018 to September 4, 2018. (Cannarozzi, N) (Main Document 20 replaced on 8/31/2018) (Cannarozzi, N).

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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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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31, 2018 to September 4, 2018. This is Defendant’s third request for extension. Good cause

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exists to grant Defendant’s request for extension. Following the third death in the last three

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months in Counsel’s family and an emergency family matter of Counsel’s immediate family

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member that required emergency stay and surgery during the same week, Counsel took some

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additional personal leave last week and was out of the office to recoup from the several family

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tragedies. Counsel also has over 85+ pending social security cases, which require two or more

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dispositive motions a week until mid-October, as well as a pending Ninth Circuit case (due in
JS for Extension of Time; 2:17-cv-02539-EFB

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early October) and several civil rights matters that require immediate investigation. Due to

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current workload demands and unanticipated leave, Counsel did not have sufficient time to

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finalize Defendant’s response. As such, Defendant needs additional time to adequately review

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the transcript and properly respond to Plaintiff’s Motion for Remand. Defendant makes this

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request in good faith with no intention to unduly delay the proceedings. Counsel apologizes for

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the belated request, but did not anticipate taking additional leave. The parties further stipulate

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that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: August 31, 2018

/s/ *Jesse Kaplan
(*as authorized by email on August 30, 2018)
JESSE KAPLAN
Attorney for Plaintiff

Dated: August 31, 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 31, 2018

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_________________________
HON. EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time; 2:17-cv-02539-EFB

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