Filed: Sep. 22, 2017
Latest Update: Sep. 22, 2017
Summary: UNOPPOSED MOTION FOR EXTENSION OF TIME (SECOND REQUEST) CAM FERENBACH , Magistrate Judge . Defendant Carolyn W. Colvin, Acting 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 September 18, 2017, by 30 days, through and including October 18, 2017. This request is made in good faith with no intention to unduly delay the proceedings
Summary: UNOPPOSED MOTION FOR EXTENSION OF TIME (SECOND REQUEST) CAM FERENBACH , Magistrate Judge . Defendant Carolyn W. Colvin, Acting 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 September 18, 2017, by 30 days, through and including October 18, 2017. This request is made in good faith with no intention to unduly delay the proceedings...
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UNOPPOSED MOTION FOR EXTENSION OF TIME
(SECOND REQUEST)
CAM FERENBACH, Magistrate Judge.
Defendant Carolyn W. Colvin, Acting 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 September 18, 2017, by 30 days, through and including October 18, 2017. This request is made in good faith with no intention to unduly delay the proceedings.
An extension of time is needed because this case was recently reassigned to the undersigned agency counsel, whose existing work commitments preclude him from adequately researching the factual and legal issues in the instant case prior to September 18, 2017. In particular, on September 11 and 12, 2017, the undersigned agency counsel participated in last-minute, work-related travel to present oral arguments in a case before the Central District of California and conduct a training presentation for the agency's Downtown Los Angeles Office of Disability Adjudication and Review. Moreover, the undersigned agency counsel is currently responsible for performing a range of tasks concurrent with drafting the Commissioner's brief in the instant case, including: drafting briefs and summary judgment motions and negotiating (or litigating) attorney fees in cases before federal district courts; drafting the Commissioner's answering brief in a Social Security case before the Ninth Circuit; preparing for a hearing in personnel-related litigation pending before the Merit Systems Protection Board; overseeing ongoing discovery in personnel-related litigation before the Equal Employment Opportunity Commission; assisting with nationally implementing the terms of a class action settlement where the agency was a party; and preparing training materials and conducting presentations for the agency's Office of Disability Adjudication and Review.
Counsel for Defendant conferred with Plaintiff's counsel, Cyrus Safa by email on September 14, 2017, who has no opposition to this motion.
IT IS SO ORDERED.
