Filed: Jul. 10, 2019
Latest Update: Jul. 10, 2019
Summary: STIPULATION FOR EXTENSION OF TIME AND PROPOSED ORDER EDMUND F. BRENNAN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Zak Franklin Hay (Plaintiff) and Andrew Saul, 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 sixty (60) days to file his Opposition to Plaintiff's Opening Brief. The current due date is July 10, 2019. The new date will be Septembe
Summary: STIPULATION FOR EXTENSION OF TIME AND PROPOSED ORDER EDMUND F. BRENNAN , Magistrate Judge . IT IS HEREBY STIPULATED, by and between Zak Franklin Hay (Plaintiff) and Andrew Saul, 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 sixty (60) days to file his Opposition to Plaintiff's Opening Brief. The current due date is July 10, 2019. The new date will be September..
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STIPULATION FOR EXTENSION OF TIME AND PROPOSED ORDER
EDMUND F. BRENNAN, Magistrate Judge.
IT IS HEREBY STIPULATED, by and between Zak Franklin Hay (Plaintiff) and Andrew Saul, 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 sixty (60) days to file his Opposition to Plaintiff's Opening Brief. The current due date is July 10, 2019. The new date will be September 10, 2019. All other deadlines will extend according to the Court's Scheduling Order.
Defense counsel needs an extension of time because she needs more time to complete review and analysis of the 2,000 page record, consider the issues raised in Plaintiff's 38 page brief, including a novel military substantial gainful activity issue, determine whether options exist for settlement, accommodate competing workload demands (including seven other briefs due this month), draft the response, go through the necessary in-house reviews, and go on vacation with family in August. Defense counsel's office has three attorneys out on extended leave and at this time, management has been unable to transfer this case to another attorney to handle due to everyone having a full caseload. This request is made in good faith with no intention to delay unduly the proceedings. Counsel apologizes to the Court, Plaintiff, and counsel for any inconvenience this delay may cause.
This is Defendant's first request for an extension.
Respectfully submitted,
Dated: July 2, 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/ Robert Weems
Robert Weems
Weems Law Office
Attorney for Plaintiff
(*As authorized via e-mail on July 2, 2019)
ORDER
GOOD CAUSE APPEARING, PURSUANT TO STIPULATION, DEFENDANT SHALL FILE HIS OPPOSITION TO PLAINTIFF'S OPENING BRIEF MOTION FOR SUMMARY JUDGMENT AND/OR REMAND ON OR BEFORE SEPTEMBER 10, 2019.
