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Salazar v. Berryhill, 2:18-cv-01096-DMC. (2019)

Court: District Court, E.D. California Number: infdco20190405c67 Visitors: 6
Filed: Apr. 04, 2019
Latest Update: Apr. 04, 2019
Summary: STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE DENNIS M. COTA , Magistrate Judge . IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her response to Plaintiff's summary judgment motion with the Court by 21 days to April 29, 2019, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's second request for an extension of time in this matter and she r
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STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE

IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file her response to Plaintiff's summary judgment motion with the Court by 21 days to April 29, 2019, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's second 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 is currently responsible for performing a range of tasks that preclude drafting the Commissioner's response to Plaintiff's opening brief by April 8, 2019, such as: preparing for an oral argument in a Social Security matter before the Ninth Circuit, scheduled for April 8, 2019; drafting briefs in Social Security cases before the district courts within the Ninth Circuit; negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act before the district courts within the Ninth Circuit; assisting with the training of newly hired attorneys in the agency's Office of the General Counsel, Region IX; and conducting discovery and preparing for a hearing scheduled for April 30-May 2, 2019 in personnel litigation pending before the Merit Systems Protection Board. Moreover, because a supervisor in Defendant's Office of the General Counsel, Region IX is currently serving as a juror on a five-week trial, the undersigned attorney for Defendant has assumed shared responsibility for overseeing the office's program litigation workload throughout Nevada, California, Arizona, and Hawaii until approximately the second week of April.

Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by thior Plaintiff

ORDER

APPROVED AND SO ORDERED.

Source:  Leagle

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