Oganesyan v. Commissioner of Social Security
Filing
17
STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 07/02/18 ORDERING that the time for responding to Plaintiff's Motion for Summary Judgment is EXTENDED to 07/05/18.(Benson, A.)
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
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 for one
22
additional week from June 28, 2018 to July 5, 2018. This is Defendant’s third request for
23
extension. Good cause exists to grant Defendant’s request for extension. Since the date of
24
Counsel’s last request for attending her uncle’s funeral, Counsel has been experiencing chronic
25
migraines, which impair her vision and was out on sick leave on the date of the current filing
26
deadline. As such, Counsel needs additional time to properly respond to Plaintiff’s Motion for
27
Summary Judgment. Defendant makes this request in good faith with no intention to unduly
28
delay the proceedings. Counsel apologizes for the belated request, but did not anticipate needing
JS for Extension of Time and PO; 2:17-cv-02541-EFB
1
1
additional leave due to her medical issues. The parties further stipulate that the Court’s
2
Scheduling Order shall be modified accordingly.
3
4
Dated: June 28, 2018
/s/ *Stuart T. Barasch
(*as authorized by email on June 28, 2018)
STUART T. BARASCH
Attorney for Plaintiff
Dated: June 28, 2018
MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
5
6
7
8
9
10
11
By
12
13
14
ORDER
15
16
/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
APPROVED AND SO ORDERED.
17
18
DATED: July 2, 2018.
19
20
21
22
23
24
25
26
27
28
JS for Extension of Time and PO; 2:17-cv-02541-EFB
2
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?