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Mitchell v. Berryhill, 2:18-cv-01798-DMC. (2019)

Court: District Court, E.D. California Number: infdco20190516899 Visitors: 2
Filed: May 15, 2019
Latest Update: May 15, 2019
Summary: STIPULATION AND ORDER FOR A THIRTY-DAY EXTENSION FOR DEFENDANT TO FILE HER CROSS-MOTION FOR SUMMARY JUDGMENT DENNIS M. COTA , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Bobby Mitchell (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that Defendant shall have an extension of time of thirty (30) days to file her Cross-Motion for Summary Judgment. The current due date is May 16, 2019. The
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STIPULATION AND ORDER FOR A THIRTY-DAY EXTENSION FOR DEFENDANT TO FILE HER CROSS-MOTION FOR SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by and between Bobby Mitchell (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that Defendant shall have an extension of time of thirty (30) days to file her Cross-Motion for Summary Judgment. The current due date is May 16, 2019. The new due date will be June 17, 2019 (because the thirtieth day, June 15, 2019, is a Saturday). The parties further stipulate that all other dates will be extended accordingly.

Defendant requests this extension because the attorney responsible for briefing this case is new to the office of the undersigned attorney for Defendant, requiring additional time for review by the undersigned attorney, who remains counsel of record. Additionally, the attorney responsible for briefing this case has another brief due in a district court case on May 15, 2019, and an oral argument in a case before this Court's Fresno Division on May 16, 2019. In addition, the undersigned attorney for Defendant is exclusively responsible for reviewing the work of two new attorneys, as well as being responsible for conducting training for all new attorneys in the undersigned's office. A thirty-day extension will give sufficient time for the assigned attorney to complete Defendant's Cross-Motion for Summary Judgment, and for the undersigned attorney for Defendant to review the motion and file it. Counsel for Plaintiff has no objection to the requested extension. This request is made in good faith with no intention to unduly delay the proceedings.

Respectfully submitted, Date: May 10, 2019 s/Jacqueline A. Forslund _________________________ JACQUELINE A. FORSLUND Attorney for Plaintiff (by email authorization) MCGREGOR W. SCOTT United States Attorney DATE: May 10, 2019 By s/Daniel P. Talbert ______________________ DANIEL P. TALBERT Special Assistant United States Attorney Attorneys for Defendant

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Source:  Leagle

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