Hastie v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 11/26/18 EXTENDING Defendant's time until 1/2/19 to respond to Plaintiff's Motion for Summary Judgment. (Kastilahn, A)

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1 2 3 4 5 6 7 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration MARGARET BRANICK-ABILLA, CSBN 223600 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8929 Facsimile: (415) 744-0134 E-Mail: Margaret.Branick-Abilla@ssa.gov 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 JORDAN MARK SAMFORD HASTIE, 14 Plaintiff, 15 vs. 16 17 NANCY A. BERRYHILL, Acting Commissioner of Social Security, 18 Defendant. 19 20 ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:18-cv-00898-CKD STIPULATION AND [PROPOSED] ORDER FOR EXTENSIONN OF TIME IT IS HEREBY STIPULATED, by and between the parties through their respective 21 counsel of record, with the approval of the Court, that Defendant shall have a 35-day extension 22 of time, from November 28, 2018 to January 2, 2019, to respond to Plaintiff’s Motion for 23 Summary Judgment. All other dates in the Court’s Scheduling Order shall be extended 24 accordingly. 25 This is Defendant’s first request for an extension of time. Defendant respectfully submits 26 that good cause exists for the requested extension because the undersigned counsel for Defendant 27 has been out on leave and needs additional time to complete her review of the sizable 28 administrative record, to evaluate the issues raised in Plaintiff’s Motion, to determine whether Stipulation & [Proposed] Order Case No. 2:18-cv-00898-CKD 1 1 options exist for settlement, and to accommodate competing workload demands. Plaintiff does 2 not oppose Defendant’s request for an extension of time. 3 Respectfully submitted, 4 5 Dated: November 23, 2018 OSTERHOUT BERGER DISABILITY LAW LLC 6 By: /s/ Lindsay F. Osterhout* Lindsay F. Osterhout Attorneys for Plaintiff [*As authorized by e-mail on Nov. 23, 2018] 7 8 9 10 Dated: November 26, 2018 11 12 13 MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 14 By: /s/ Margaret Branick-Abilla MARGARET BRANICK-ABILLA Special Assistant United States Attorney Attorneys for Defendant 15 16 17 18 [PROPOSED] ORDER 19 20 Pursuant to stipulation, IT IS SO ORDERED. 21 22 23 Dated: November 26, 2018 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 Stipulation & [Proposed] Order Case No. 2:18-cv-00898-CKD 2

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