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Havsgaard v. Berryhill, 1:18-cv-00944-GSA. (2019)

Court: District Court, E.D. California Number: infdco20190613995 Visitors: 15
Filed: Jun. 12, 2019
Latest Update: Jun. 12, 2019
Summary: JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S OPENING BRIEF GARY S. AUSTIN , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Opening Brief be extended from June 11, 2019 to June 28, 2019. This is Defendant's third request for extension Good cause exists to grant Defendant's request for extension. As the Court is aware, Counsel for Defendant (Cou
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JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S OPENING BRIEF

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Opening Brief be extended from June 11, 2019 to June 28, 2019. This is Defendant's third request for extension Good cause exists to grant Defendant's request for extension. As the Court is aware, Counsel for Defendant (Counsel) had multiple family tragedies last month, including the death of her two cousins, and uncle, and a family friend. Counsel has also been taking care of her elderly mother, who had surgery in late May and another follow up surgery last week. In addition, Counsel has over 100+ active matters, which require two or more dispositive motions per week until August. In addition, Counsel has had migraine symptoms, which includes impaired vision, as of the current filing deadline. As such, Counsel respectfully requests additional time to adequately review the transcript and respond to the issues raised in Plaintiff's Opening Brief. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Defendant apologizes for the belated request for extension, but made this request as soon as reasonably practicable. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

Respectfully submitted, Dated: June 11, 2019 /s/ * Jonathan Pena (*as authorized by email on June 11, 2019) JONATHAN PENA Attorney for Plaintiff Dated: June 11, 2019. McGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration By /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant

IT IS SO ORDERED.

Source:  Leagle

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