Calleres v. Saul, 1:19-00513-EPG. (2020)
Court: District Court, E.D. California
Number: infdco20200213c13
Filed: Feb. 12, 2020
Latest Update: Feb. 12, 2020
Summary: STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file his response to Plaintiff's opening brief with the Court by 30 days to March 19, 2020, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and he requests i
Summary: STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE ERICA P. GROSJEAN , Magistrate Judge . IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file his response to Plaintiff's opening brief with the Court by 30 days to March 19, 2020, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and he requests it..
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STIPULATION AND ORDER TO EXTEND BRIEFING SCHEDULE
ERICA P. GROSJEAN, Magistrate Judge.
IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend Defendant's time to file his response to Plaintiff's opening brief with the Court by 30 days to March 19, 2020, and that all other scheduling dates set forth in the Court's Case Management Order shall be extended accordingly. This is Defendant's first request for an extension of time in this matter and he 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 responsible for performing a range of tasks that preclude drafting the Commissioner's response to Plaintiff's opening brief by February 18, 2020, such as: drafting an answering brief in two Social Security cases pending before the Ninth Circuit; drafting briefs in Social Security cases before the district courts within the Ninth Circuit; and negotiating (or litigating) attorney fee matters under the Equal Access to Justice Act before the Ninth Circuit and district courts within the Ninth Circuit. Additionally, counsel for Defendant is relocating to Chicago, Illinois in February 2020, and this extension will allow him to prepare the Commissioner's responsive brief without disruption from the scheduled leave associated with this relocation. Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay.
Respectfully submitted,
Date: February 12, 2020 McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
By: /s/Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant
Date: February 12, 2020 NEWEL LAW
By: /s/Asim H. Modi for Melissa Newel*
MELISSA NEWEL
*Authorized by email on February 12, 2020
Attorney for Plaintiff
ORDER
Upon review of the parties' stipulation (ECF No. 17) the Court finds good cause to approve same. Accordingly, IT IS ORDERED that Defendant's response to Plaintiff's opening brief shall be filed on or before March 19, 2020, with all other deadlines in the Scheduling Order extended accordingly.
IT IS SO ORDERED.
Source: Leagle