Oganesyan v. Commissioner of Social Security

Filing 31

ORDER signed by Magistrate Judge Edmund F. Brennan on 11/10/2022 EXTENDING 29 to 12/9/2022, that the time for Defendant to respond to Plaintiff's Motion for Contempt.(Reader, L)

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

ZHANNA OGANESYAN,

14

Plaintiff,

15

vs.

16
17

KILOLO KIJAKAZI ,
Acting Commissioner of Social Security

18

Defendant.

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

Case No.: 2:17-cv-02541-EFB
JOINT STIPULATION AND
[PROPOSED] ORDER TO MODIFY
BRIEFING SCHEDULE FOR
PLAINTIFF’S MOTION TO CONTEMPT
(DKT 29).

19
20

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

21

that the time for Defendant to respond to Plaintiff’s Motion for Contempt (Motion) (Dkt. 29) be

22

extended from November 9, 2022 to December 9, 2022. This is the parties’ first request for

23

extension to modify the briefing schedule for Plaintiff’s Motion. Good cause exists to grant the

24

request for extension. Counsel for Defendant needs additional time to research the issues

25

presented in Plaintiff’s Motion and respond. In addition, last month, Counsel for Defendant and

26

her elderly mother had COVID and was out on leave. Counsel is the primary caregiver for her

27

mother.

28

///
Joint Stipulation for Extension of Time and PO; 2:17-cv-02541-EFB
1

1

The parties make this request in good faith with no intention to unduly delay the proceedings.

2
3
4
5

Respectfully submitted,
Dated: November 9, 2022

/s/ *Stuart Barasch
(*as authorized by email)
STUART BARASCH
Attorney for Plaintiff

Dated: November 9, 2022

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

6
7
8
9
10
11
12
By

13
14
15
16

.
ORDER

17
18

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

APPROVED AND SO ORDERED:

19
20
21

DATED: November 10, 2022.

22
23
24
25
26
27
28
Joint Stipulation for Extension of Time and PO; 2:17-cv-02541-EFB
2