2:19-cv-00537 | E.D. Cal. | Dec 17, 2019

MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration TINA L. NAICKER, CSBN 252766 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 268-5611 Facsimile: (415) 744-0134 E-Mail: Tina.Naicker@SSA.gov Attorneys for Defendant

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:19-cv-00537-KJN ROBERTO DIAZ, JOINT STIPULATION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT AND ORDER Plaintiff, vs. ANDREW SAUL Commissioner of Social Security, Defendant. IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for Defendant to respond to Plaintiff’s Motion for Summary Judgment be extended from December 13, 2019 to January 15, 2020 . This is Defendant’s second request for extension. Good cause exists to grant Defendant’s request for extension. Counsel was injured during her vacation last week and needs some additional time to recover from her accident. In addition, Counsel also has over 100+ active social security matters, which require two more dispositive motions until mid-December, and two pending Ninth Circuit matters which require multiple levels of review with due dates of December 20th and 23rd, 2019. Due to unanticipated leave and heavy caseload, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff’s Motion for Summary Judgment. The parties further stipulate that 1 JS for Extension of Time and PO; 2:19-cv-00537-KJN 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, as Counsel has been out of the office.

Respectfully submitted, Dated: December 13, 2019 /s/ Steven H. Berniker (*as authorized by email on December 13, 2019

STEVEN HARRIS BERNIKER

Attorney for Plaintiff

Dated: December 13, 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:

Dated: December 17, 2019 diaz.537 2 JS for Extension of Time and PO; 2:19-cv-00537-KJN