Johnson v. Commissioner of Social Security

Filing 30

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 11/19/18 ORDERING that Defendant shall respond to Plaintiff's motion for summary judgment by 12/03/18. Plaintiff shall file any reply by 12/17/18. All other deadlines are modified accordingly. (Benson, A.)

1
2
3
4
5
6
7
8

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: 415-744-0134
E-mail: [e-mail]
Attorneys for DEFENDANT

9
10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA

12

FRESNO

13
14
15
16
17
18

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

LORENA ANGELA JOHNSON,
Plaintiff,
vs.
NANCY A. BERRYHILL, Acting
Commissioner Of Social Security,
Defendant.

19
20
21
22
23
24
25

CASE NO. 2:18-cv-00005-DMC
STIPULATION TO EXTEND TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

LORENA ANGELA JOHNSON (Plaintiff) and NANCY A. BERRYHILL, Acting
Commissioner Of Social Security (Defendant or the Commissioner), hereby stipulate, subject to
the approval of the Court, to a 14-day extension of time for Defendant to respond to Plaintiff’s
Motion for Summary Judgment (Docket Number 27). This is the fourth request for an extension
of time sought in the above-captioned matter, and it is Defendant’s first request for additional
time. The current deadline is November 19, 2018, and the new deadline would be December 3,
2018. Defendant requests this additional time because her undersigned counsel was

26
unexpectedly out of the office on medical leave during the week of November 5, 2018. As a
27
result, the undersigned defense counsel requires additional time to adequately address the issues
28
STIPULATION FOR EXTENSION OF TIME

1

CASE NO. 2:18-cv-00005-DMC

1
2

Plaintiff raises in her motion for summary judgment. The parties further stipulate that the
scheduling order in the above-captioned matter be modified accordingly.

3

Respectfully submitted,

4
CERNEY KREUZE & LOTT, LLP

5
6

Dated: November 15, 2018

By: /s/ Shellie Lott*
SHELLIE LOTT
Attorney for Plaintiff
[*As authorized by e-mail on November 15, 2018

Dated: November 15, 2018

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

7
8
9
10
11
12

By:
/s/ Sharon Lahey
SHARON LAHEY
Assistant Regional Counsel

13
14
15
16

ORDER

17
18

Pursuant to the parties’ stipulation, IT IS SO ORDERED. Defendant shall respond to

19

Plaintiff’s motion for summary judgment on or before December 3, 2018. Plaintiff shall file any

20

reply on or before December 17, 2018. All other deadlines are modified accordingly.

21
22
23
24

Dated: November 19, 2018
____________________________________
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

25
26
27
28
STIPULATION FOR EXTENSION OF TIME

2

CASE NO. 2:18-cv-00005-DMC