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Malveaux v. Berryhill, 2:18-cv-01952-DMC. (2019)

Court: District Court, E.D. California Number: infdco20190522890 Visitors: 12
Filed: May 20, 2019
Latest Update: May 20, 2019
Summary: STIPULATION AND ORDER FOR AN EXTENSION OF TIME OF 45 DAYS FOR DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT DENNIS M. COTA , Magistrate Judge . IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of 45 additional days to respond to Plaintiff's opening brief. The current due date is May 16, 2019. The new due date will be June 30, 2019. This is Defendant's first request for an extens
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STIPULATION AND ORDER FOR AN EXTENSION OF TIME OF 45 DAYS FOR DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that Defendant shall have an extension of time of 45 additional days to respond to Plaintiff's opening brief. The current due date is May 16, 2019. The new due date will be June 30, 2019.

This is Defendant's first request for an extension of time for briefing and the fourth request in this case overall. There is good cause for this request. Since the filing of Plaintiff's motion for summary judgment, Defendant's counsel has been addressing a full workload and backlog of district court cases and other matters. Starting April 17, 2019, Defendant's counsel has had at least 17 district court and bankruptcy court matters. Defendant's counsel has shifted and is continuing to shift many of her cases to avoid missing the deadlines of her cases and minimize further delay of her older cases to which she is giving priority where possible. In addition, many of Defendant's counsel's cases required her to take additional time to complete. Defendant's counsel also has at least 23 other scheduled matters in the next month and a half, along with pre-approved leave in May.

Thus, Defendant is respectfully requesting additional time up to and including June 30, 2019, to respond to Plaintiff's motion for summary judgment. This request is made in good faith with no intention to unduly delay the proceedings.

Respectfully submitted, Date: May 15, 2019 JESSE S. KAPLAN, ATTORNEY AT LAW s/Jesse S. Kaplan by C.Chen* (As authorized by email on 5/14/2019) JESSE S. KAPLAN Attorney for Plaintiff Date: May 15, 2019 MCGREGOR W. SCOTT United States Attorney Bys/Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney Attorneys for Defendant

ORDER

APPROVED AND SO ORDERED.

Source:  Leagle

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