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Kane v. Saul, 2:19-cv-01584-AC. (2020)

Court: District Court, E.D. California Number: infdco20200320691 Visitors: 30
Filed: Mar. 18, 2020
Latest Update: Mar. 18, 2020
Summary: DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION (FIRST REQUEST) AND PROPOSED ORDER ALLISON CLAIRE , Magistrate Judge . Defendant requests an extension of thirty (30) days in which to file his Response to Plaintiff's Brief in Support of Remand, extending the current due date from March 19, 2020, to the new due date of Monday, April 20, 2020. This is Defendant's first request for an extension to file his Response to Plaintiff's Brief in Support of Remand. Counsel for Defendant conferred wi
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DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION (FIRST REQUEST) AND PROPOSED ORDER

Defendant requests an extension of thirty (30) days in which to file his Response to Plaintiff's Brief in Support of Remand, extending the current due date from March 19, 2020, to the new due date of Monday, April 20, 2020. This is Defendant's first request for an extension to file his Response to Plaintiff's Brief in Support of Remand. Counsel for Defendant conferred with counsel for Plaintiff, Larry Rohlfing, on March 18, 2020. Counsel for Plaintiff confirmed that Plaintiff had no objections to this request.

Counsel for Defendant states that this case was recently reassigned to her at the briefing stage after the previously assigned lead counsel resigned from Social Security Administration Office of General Counsel (SSA OGC). Counsel states that she had four District Court briefs with due dates from March 16, 2020, through March 20, 2020, along with other program litigation and administrative responsibilities, and is unable to complete these assignments adequately as scheduled within the current due dates. Scheduling issues are exacerbated by recent resignations and medical leave absences of OGC staff, coupled with OGC's long-term hiring freeze, necessitating reassignment of this and other cases mid-stream. Counsel states that the difficulty has been further compounded by recent interruptions in access to SSA's secure network, and difficulty accessing documents through the Court's ecf system.

Defendant makes this request in good faith, with no intention of unnecessary delay. Counsel for Defendant sincerely apologizes to the Court and Plaintiff for any inconvenience caused by this request. Defendant asks that all other deadlines be adjusted accordingly.

Respectfully submitted, Dated: March 18, 2020 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 U.S. Attorney Attorneys for Defendant

ORDER

For good cause shown, Defendant's unopposed request for extension is approved. APPROVED AND SO ORDERED.

Source:  Leagle

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