Filed: May 09, 2019
Latest Update: May 09, 2019
Summary: STIPULATION FOR EXTENSION OF TIME AND PROPOSED ORDER EDMUND F. BRENNAN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Victor Sahyoun (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that, with the Court's approval, Defendant shall have an extension of time of thirty (30) days to file her Opposition to Plaintiff's Opening Brief. The current due date is May 8, 2019. The new date will
Summary: STIPULATION FOR EXTENSION OF TIME AND PROPOSED ORDER EDMUND F. BRENNAN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Victor Sahyoun (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that, with the Court's approval, Defendant shall have an extension of time of thirty (30) days to file her Opposition to Plaintiff's Opening Brief. The current due date is May 8, 2019. The new date will b..
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STIPULATION FOR EXTENSION OF TIME AND PROPOSED ORDER
EDMUND F. BRENNAN, Magistrate Judge.
IT IS HEREBY STIPULATED, by and between Victor Sahyoun (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that, with the Court's approval, Defendant shall have an extension of time of thirty (30) days to file her Opposition to Plaintiff's Opening Brief. The current due date is May 8, 2019. The new date will be June 7, 2019. All other deadlines will extend accordingly.
Defense counsel needs an extension of time because she is a newer hire who needs more time to complete review and analysis of the record, consider the issues raised in Plaintiff's brief, determine whether options exist for settlement, accommodate competing workload demands, draft the response, and go through the necessary in-house reviews. This request is made in good faith with no intention to delay unduly the proceedings. Counsel apologizes to the Court and Plaintiff for any inconvenience this delay may cause.
This is Defendant's first request for an extension.
Respectfully submitted,
Dated: May 6, 2019 MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
By: /s/ S. Wyeth McAdam
S. WYETH McADAM
Special Assistant United States Attorney
Attorneys for Defendant
/s/ Harvey Peter Sackett
HARVEY PETER SACKETT
Sackett & Associates, A Professional Law Corporation
Attorneys for Plaintiff
(*As authorized via e-mail on May 6, 2019)
ORDER
GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, DEFENDANT SHALL FILE HER OPPOSITION TO PLAINTIFF'S OPENING BRIEF CROSS-MOTION FOR SUMMARY JUDGMENT ON OR BEFORE June 7, 20189.
