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)

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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-

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