Rumantsev v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 9/5/2018 ORDERING that the time for responding to plaintiff's motion for summary judgment is EXTENDED to 9/11/2018. (Zignago, K.)
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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
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September 4, 2018 to September 11, 2018. This is Defendant’s fourth request for extension.
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Good cause exists to grant Defendant’s request for extension. Counsel is sick and has a migraine
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on the date of the current filing deadline, which impairs her vision. Counsel attempted diligently
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to finish her response, but could not do so by the current filing deadline. Counsel is also
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expected to be out of the office on September 7th and 8th, 2018. As a result of Counsel’s
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unexpected time off, Counsel did not have sufficient time to finalize Defendant’s response. As
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such, Defendant needs additional time to adequately review the transcript and properly respond
JS for Extension of Time; 2:17-cv-02539-EFB
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to Plaintiff’s Motion for Remand. Defendant makes this request in good faith with no intention
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to unduly delay the proceedings. Counsel apologizes for the belated request, but did not
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anticipate taking additional leave. The parties further stipulate that the Court’s Scheduling Order
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shall be modified accordingly.
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Respectfully submitted,
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Dated: September 4, 2018
/s/ *Jesse Kaplan
(*as authorized by email on September 4, 2018)
JESSE KAPLAN
Attorney for Plaintiff
Dated: September 4, 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: September 5, 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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