Smith v. Saul, 1:18-cv-01614-GSA. (2019)
Court: District Court, E.D. California
Number: infdco20190816a15
Visitors: 8
Filed: Aug. 15, 2019
Latest Update: Aug. 15, 2019
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME GARY S. AUSTIN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between the parties through their respective counsel of record, with the Court's approval, that Plaintiff shall have a 45-day extension of time, from 08/19/2019 to 10/03/2019, for Plaintiff to serve on defendant with PLAINTIFF'S OPENING BRIEF. All other dates in the Court's Scheduling Order shall be extended accordingly. This is Plaintiff's third request for an extension of time.
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME GARY S. AUSTIN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between the parties through their respective counsel of record, with the Court's approval, that Plaintiff shall have a 45-day extension of time, from 08/19/2019 to 10/03/2019, for Plaintiff to serve on defendant with PLAINTIFF'S OPENING BRIEF. All other dates in the Court's Scheduling Order shall be extended accordingly. This is Plaintiff's third request for an extension of time. ..
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STIPULATION AND ORDER FOR EXTENSION OF TIME
GARY S. AUSTIN, Magistrate Judge.
IT IS HEREBY STIPULATED, by and between the parties through their respective counsel of record, with the Court's approval, that Plaintiff shall have a 45-day extension of time, from 08/19/2019 to 10/03/2019, for Plaintiff to serve on defendant with PLAINTIFF'S OPENING BRIEF. All other dates in the Court's Scheduling Order shall be extended accordingly.
This is Plaintiff's third request for an extension of time. The first two extensions were for the Plaintiff's Confidential Letter Brief. During that period, Plaintiff was attempting to secure an OCR version of the Certified Administrative Record. We were able to do so after the second extension. (Doc. 16 & 17)
Good cause exists for this request. During the month of August and September, Counsel is undertaking several continuing legal education programs in addition to several merit briefs, administrative hearings, and district court hearings. On the week the brief is currently due, Plaintiff has twelve administrative hearings before Administrative Law Judges, and one District Court hearing in another matter. Additionally, during the next three weeks, counsel is completing continuing education classes to continue certification as a Resource Family as part of the Fresno County's Foster Care system. Lastly, Counsel hopes to attend the legal education conference from 9/11/2019 — 9/14/2019 with the National Organization of Social Security Representatives. Defendant does not oppose the requested extension. Counsel apologizes to the Defendant and Court for any inconvenience this may cause.
Respectfully submitted,
Dated: August 13, 2019 PENA & BROMBERG, ATTORNEYS AT LAW
By: /s/ Jonathan Omar Pena
JONATHAN OMAR PENA
Attorneys for Plaintiff
Dated: August 13, 2019 MCGREGOR W. SCOTT,
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
By: */s/ Carol S. Clark
Carol S. Clark
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on August 13, 2019)
IT IS SO ORDERED.
FootNotes
1. Andrew Saul is now the Commissioner of Social Security and is automatically substituted as a party pursuant to Fed. R. Civ. P. 25(d). See also section 205(g) of the Social Security Act, 42 U.S.C. § 405(g)(action survives regardless of any change in the person occupying the office of Commissioner of Social Security).
Source: Leagle
