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Coats v. Berryhill, 2:18-cv-02298-EFB. (2019)

Court: District Court, E.D. California Number: infdco20190424870 Visitors: 6
Filed: Apr. 23, 2019
Latest Update: Apr. 23, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S OPENING BRIEF FILE CROSS-MOTION FOR SUMMARY JUDGMENT EDMUND F. BRENNAN , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for Defendant to file her response to Plaintiff's Opening Brief cross-motion for summary judgment be extended from April 17, 2019 to May 21, 2019. This is Defendant's first request for extension. Goo
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S OPENING BRIEF FILE CROSS-MOTION FOR SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for Defendant to file her response to Plaintiff's Opening Brief cross-motion for summary judgment be extended from April 17, 2019 to May 21, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Last month, Counsel for Defendant (Counsel) was terribly ill with the flu and pneumonia and was out of the office for two and half weeks on intermittent sick leave. Counsel also was out for her chronic migraines, which impair her vision. In addition, Counsel has over 80+ active matters, which require two or more dispositive motions per week until mid-May. Due to unexpected leave and heavy workload, 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 following her sick leave. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

Respectfully submitted, Dated: April 12, 2019 /s/ Shellie Lott ------------------------------ (*as authorized by email on April 12, 2019 SHELLIE LOTT Attorney for Plaintiff Dated: April 12, 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

ORDER

APPROVED AND SO ORDERED.

Source:  Leagle

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