Filed: Dec. 19, 2019
Latest Update: Dec. 19, 2019
Summary: STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND PROPOSED ORDER EDMUND F. BRENNAN , Magistrate Judge . Plaintiff and Defendant, through their respective attorneys, and subject to the approval of the Court, hereby stipulate that Defendant shall have an extension of time of 60 days, up to and including Tuesday, February 18, 2020, in which to file and serve his response to Plaintiff's Motion for Summary Judgment. Plaintiff shall ha
Summary: STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND PROPOSED ORDER EDMUND F. BRENNAN , Magistrate Judge . Plaintiff and Defendant, through their respective attorneys, and subject to the approval of the Court, hereby stipulate that Defendant shall have an extension of time of 60 days, up to and including Tuesday, February 18, 2020, in which to file and serve his response to Plaintiff's Motion for Summary Judgment. Plaintiff shall hav..
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STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND PROPOSED ORDER
EDMUND F. BRENNAN, Magistrate Judge.
Plaintiff and Defendant, through their respective attorneys, and subject to the approval of the Court, hereby stipulate that Defendant shall have an extension of time of 60 days, up to and including Tuesday, February 18, 2020, in which to file and serve his response to Plaintiff's Motion for Summary Judgment. Plaintiff shall have 15 days, up to and including March 4, 2020, to file and serve her optional reply.
Defense counsel needs an extension of time because the attorney responsible for briefing needs additional time to complete review and analysis of the 3,000-page 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. With regard to competing workload demands, in December, defense counsel has seven additional District Court briefs due, all but one of which courts have already extended once. In December, defense counsel is taking leave to assist her family settle her in-law's estate and three days off to be with family traveling from out of town for the holidays. Currently, the Office of the General Counsel has undergone an unforeseen reduction of several staff attorneys; Social Security is under a hiring freeze and management would have difficulty reassigning this case to another attorney. 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 to file a response to Plaintiff's Motion for Summary Judgment.
Respectfully submitted,
Dated: December 18, 2019 McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Office of General Counsel
Social Security Administration
By: /s/ S. Wyeth McAdam
S. WYETH McADAM
Special Assistant United States Attorney
Attorneys for Defendant
/s/ Jacqueline Anna Forslund*
JACQUELINE ANNA FORSLUND
Forslund Law LLC
Attorney for Plaintiff
(* As authorized via e-mail on December 18, 2019)
ORDER
GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, DEFENDANT SHALL FILE HIS OPPOSITION TO PLAINTIFF'S OPENING BRIEF CROSS-MOTION FOR SUMMARY JUDGMENT ON OR BEFORE FEBRUARY 18, 2020. PLAINTIFF'S OPTIONAL RETLY US DUE ON OR BEFORE MARCH 4, 2010.
