Schultz v. Saul, 2:19-cv-00096-RFB-BN. (2019)
Court: District Court, D. Nevada
Number: infdco20190702c16
Visitors: 20
Filed: Jun. 27, 2019
Latest Update: Jun. 27, 2019
Summary: UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST) BRENDA WEKSLER , Magistrate Judge . Defendant Andrew Saul, Commissioner of Social Security ("Defendant") respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm and Response to Plaintiff's Motion for Reversal, due on July 1, 2019, by 30 days, through and including July 31, 2019. This request is made in good faith with no intention to unduly delay the proceedings. An extension of t
Summary: UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST) BRENDA WEKSLER , Magistrate Judge . Defendant Andrew Saul, Commissioner of Social Security ("Defendant") respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm and Response to Plaintiff's Motion for Reversal, due on July 1, 2019, by 30 days, through and including July 31, 2019. This request is made in good faith with no intention to unduly delay the proceedings. An extension of ti..
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UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)
BRENDA WEKSLER, Magistrate Judge.
Defendant Andrew Saul, Commissioner of Social Security ("Defendant") respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm and Response to Plaintiff's Motion for Reversal, due on July 1, 2019, by 30 days, through and including July 31, 2019. This request is made in good faith with no intention to unduly delay the proceedings.
An extension of time is needed because counsel for Defendant is responsible for performing a range of tasks that preclude drafting the Commissioner's response to Plaintiff's summary judgment motion by July 1, 2019, such as: drafting answering briefs in two Social Security cases pending before the Ninth Circuit; drafting briefs in Social Security cases before the district courts within the Ninth Circuit; negotiating (or litigating) attorney fee matters pursuant to the Equal Access to Justice Act before the district courts within the Ninth Circuit; assisting with the training of a newly hired attorney in the agency's Office of the General Counsel, Region IX; and conducting substantive and logistical preparation for an arbitration involving the agency and one of the agency's collective bargaining units.
Counsel for Defendant conferred with Plaintiff's counsel, Cyrus Safa by email on June 27, 2019, who has no opposition to this motion.
Respectfully submitted this 27th day of June 2019.
NICHOLAS A. TRUTANICH
United States Attorney
/s/Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
OF COUNSEL:
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
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 USC 405(g) (action survives regardless of any change in the person occupying the office of Commissioner of Social Security).
Source: Leagle
