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Langston v. Berryhill, 2:18-cv-00658-DMC. (2019)

Court: District Court, E.D. California Number: infdco20190422a28 Visitors: 20
Filed: Apr. 19, 2019
Latest Update: Apr. 19, 2019
Summary: JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME DENNIS M. COTA , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record that the time for responding to Plaintiff's Motion Summary Judgment be extended from April 18, 2019 to April 22, 2019 . This is Defendant's fourth request for extension. Good cause exists to grant Defendant's request for extension. Counsel for Defendant (Counsel) had a personal family emergency this week and was unexpect
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JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record that the time for responding to Plaintiff's Motion Summary Judgment be extended from April 18, 2019 to April 22, 2019. This is Defendant's fourth request for extension. Good cause exists to grant Defendant's request for extension. Counsel for Defendant (Counsel) had a personal family emergency this week and was unexpectedly out of the office following the death of her uncle and two cousins. Counsel also has over 100+ active social security matters, which require two or more dispositive motions per week until mid-June. Due unexpected leave and heavy workload, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Summary Judgment. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Counsel apologizes for the belated request, but made her request as soon as reasonably practicable.

Respectfully submitted, Dated: April 18, 2019 /s/ *Laura Krank (*as authorized by email on April 18, 2019) LAURA KRANK Attorney for Plaintiff Dated: April 18, 2019 McGREGOR W. SCOTT Acting 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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