Oganesyan v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 6/27/18: The time for responding to Plaintiff's Motion for Summary Judgment shall be extended from June 25, 2018 to June 28, 2018. (Kaminski, H)

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

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
15
16
17

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

18

)
)
)
)
)
)
)
)
)
)
)
)

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

19
20

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,

21

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

22

25, 2018 to June 28, 2018. This is Defendant’s second request for extension. Good cause

23

exists to grant Defendant’s request for extension. Counsel attended a funeral on the date of the

24

current filing deadline and is attending prayer services thereafter. In addition, Counsel has over

25

75+ pending social security cases, which require two or more dispositive motions a week until

26

early August. Due to current workload demands and upcoming leave, Counsel needs additional

27

time to adequately review the transcript and properly respond to Plaintiff’s Motion for Summary

28

Judgment. Defendant makes this request in good faith with no intention to unduly delay the
JS for Extension of Time and PO; 2:17-cv-02541-EFB

1

1

proceedings. Counsel apologizes for the belated request, but did not anticipate being out on the

2

current filing deadline due to the unexpected death of a family member. The parties further

3

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

4
5

Respectfully submitted,

6
7

Dated: June 25, 2018

/s/ *Stuart T. Barasch
(*as authorized by Ted Wicklund via email for
Stuart T. Barasch on June 25, 2018)
STUART T. BARASCH
Attorney for Plaintiff

Dated: June 25, 2018

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

8
9
10
11
12
13
14
15

By

16
17
18

/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

19
20
21
22
23

APPROVED AND SO ORDERED.

DATED: June 27, 2018.

____________________________________
HON. EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28
JS for Extension of Time and PO; 2:17-cv-02541-EFB

2