Hall-Kanellis v. Commissioner of Social Security
Filing
16
ORDER signed by Magistrate Judge Allison Claire on 8/21/18 EXTENDING defendant's time to file her summary judgment motion with the Court by 30 days to 9/26/18, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. (Becknal, R)
1
2
3
4
5
6
7
8
MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI, NYSBN 4692018
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: 415-977-8952
Facsimile: 415-744-0134
Email: asim.modi@ssa.gov
Attorneys for Defendant
9
UNITED STATES DISTRICT COURT
10
EASTERN DISTRICT OF CALIFORNIA
11
SACRAMENTO DIVISION
12
13
CATHERINE HALL-KANELLIS,
14
Plaintiff,
15
v.
16
17
18
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.
19
20
21
22
23
24
25
26
27
28
)
)
)
)
)
)
)
)
)
)
)
Case No.: 2:18-cv-00301-AC
STIPULATION AND [PROPOSED]
ORDER TO EXTEND BRIEFING
SCHEDULE
IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to
extend Defendant’s time to file her summary judgment motion with the Court by 30 days to
September 26, 2018, and that all other scheduling dates set forth in the Court’s Case
Management Order shall be extended accordingly. This is Defendant’s first request for an
extension of time in this matter and she requests it in good faith and without any intent to
prolong proceedings unduly.
There is good cause for this extension request because counsel for Defendant has
workload issues that preclude filing her cross-motion by August 27, 2018. In particular, counsel
for Defendant is currently responsible for performing an extensive range of tasks, such as:
-1-
1
drafting briefs and summary judgment motions (including five due in the next three weeks) in
2
Social Security cases before the district courts within the Ninth Circuit, negotiating (or litigating)
3
attorney fee matters pursuant to the Equal Access to Justice Act before the district courts within
4
the Ninth Circuit; drafting a post-hearing brief for an arbitration proceeding involving the agency
5
and one of the agency’s collective bargaining units; assisting with implementing the terms of the
6
class action settlement reached in Hart v. Berryhill (N.D.Cal. No. 3:15-cv-623-JST); and
7
preparing training materials and conducting presentations for the agency’s Office of Hearing
8
Operations. Counsel for Defendant has also been out of the office for significant portions of the
9
last three weeks for these presentations to the agency’s hearing offices.
10
11
Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused
by this delay.
12
Respectfully submitted,
13
14
Date: August 21, 2018
CERNEY KREUZE & LOTT, LLP
By:
15
16
17
18
Date: August 21, 2018
/s/ Asim H. Modi for Shellie Lott*
SHELLIE LOTT
*Authorized by email on August 21, 2018
Attorney for Plaintiff
MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
19
20
21
By:
22
23
/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant
24
ORDER
25
26
27
APPROVED AND SO ORDERED
DATED: August 21, 2018
28
-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?