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.)

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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 for one

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additional week from June 28, 2018 to July 5, 2018. This is Defendant’s third request for

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extension. Good cause exists to grant Defendant’s request for extension. Since the date of

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Counsel’s last request for attending her uncle’s funeral, Counsel has been experiencing chronic

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migraines, which impair her vision and was out on sick leave on the date of the current filing

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deadline. As such, Counsel needs additional time to properly respond to Plaintiff’s Motion for

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Summary Judgment. Defendant makes this request in good faith with no intention to unduly

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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

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additional leave due to her medical issues. The parties further stipulate that the Court’s

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Scheduling Order shall be modified accordingly.

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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

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By

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ORDER

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

APPROVED AND SO ORDERED.

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DATED: July 2, 2018.

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

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