Rumantsev v. Commissioner of Social Security

Filing 22

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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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 22 September 4, 2018 to September 11, 2018. This is Defendant’s fourth request for extension. 23 Good cause exists to grant Defendant’s request for extension. Counsel is sick and has a migraine 24 on the date of the current filing deadline, which impairs her vision. Counsel attempted diligently 25 to finish her response, but could not do so by the current filing deadline. Counsel is also 26 expected to be out of the office on September 7th and 8th, 2018. As a result of Counsel’s 27 unexpected time off, Counsel did not have sufficient time to finalize Defendant’s response. As 28 such, Defendant needs additional time to adequately review the transcript and properly respond JS for Extension of Time; 2:17-cv-02539-EFB 1 1 to Plaintiff’s Motion for Remand. Defendant makes this request in good faith with no intention 2 to unduly delay the proceedings. Counsel apologizes for the belated request, but did not 3 anticipate taking additional leave. The parties further stipulate that the Court’s Scheduling Order 4 shall be modified accordingly. 5 6 7 Respectfully submitted, 8 9 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 10 11 12 13 14 15 16 By 17 18 19 20 21 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant ORDER APPROVED AND SO ORDERED. 22 23 DATED: September 5, 2018. 24 _________________________ HON. EDMUND F. BRENNAN UNITED STATES MAGISTRATE JUDGE 25 26 27 28 JS for Extension of Time; 2:17-cv-02539-EFB 2

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