Oganesyan v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 5/30/18 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED from 5/24/18 to 6/25/18. (Becknal, R)

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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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ZHANNA OGANESYAN,
Plaintiff,
vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No.: 2:17-cv-02541-EFB
JOINT STIPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME 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,

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that the time for responding to Plaintiff’s Motion for Summary Judgment be extended from May

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24, 2018 to June 25, 2018. This is Defendant’s first request for extension. Good cause exists to

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grant Defendant’s request for extension. Counsel will be out on leave on the date of the current

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filing deadline. In addition, Counsel has over 75+ pending social security cases, which require

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two or more dispositive motions a week until early July. Counsel also has a pending Ninth

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Circuit matter that require additional levels of review and several civil rights matters which

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require imminent attention and investigation. Due to current workload demands and upcoming

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scheduled leave, Counsel needs additional time to adequately review the transcript and properly
JS for Extension of Time and PO; 2:17-cv-02541-EFB

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respond to Plaintiff’s Motion for Summary Judgment. Defendant makes this request in good

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faith with no intention to unduly delay the proceedings. The parties further stipulate that the

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Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: May 21, 2018

/s/ *Stuart T. Barasch
(*as authorized by email on May 18, 2018)
STUART T. BARASCH
Attorney for Plaintiff

Dated: May 21, 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

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APPROVED AND SO ORDERED.

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DATED: May 30, 2018.

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____________________________________
HON. EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time and PO; 2:17-cv-02541-EFB

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