Soria v. Commissioner of Social Security

Filing 33

JOINT STIPULATION FOR EXTENSION OF TIME TO MODIFY BRIEFING SCHEDULE FOR MOTION FOR ATTORNEYS FEES (Dkt. 29 ); ORDER, signed by Magistrate Judge Sheila K. Oberto on 4/26/2021. (Kusamura, W)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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CATHERINE SORIA,
Plaintiff,

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v.

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ANDREW SAUL,
Commissioner of Social Security,
Defendant.

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Case No.: 1:18-cv-00089-SKO
JOINT STIPULATION FOR EXTENSION
OF TIME TO MODIFY BRIEFING
SCHEDULE FOR MOTION FOR
ATTORNEYS FEES (Dkt. 29); ORDER
(Doc. 32)

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that the time for responding to the Motion for Attorneys Fees Pursuant to 42 U.S.C. §406(b)
(Dkt. 29) be extended from April 23, 2021 to May 21, 2021. This is Defendant’s first request for
extension. Good cause exists to grant Defendant’s request for extension. After several weeks
of intermittent leave due to Counsel for Defendant (“Counsel”) extended family member in the
Intensive Care Unit (ICU), Counsel’s extended family member passed away over the weekend.
Counsel also has over 80+ active social security matters, in various stages of litigation, including
several dispositive motions and a Ninth Circuit brief due to the U.S. Attorney’s Office. Due to

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JS for Extension of Time and Order

Case No. 1:18-cv-00089-SKO

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heavy caseload, unexpected leave, and anticipated leave for funeral and prayer services, Counsel

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needs additional time to adequately review the Motion for Attorneys Fees and provide

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Defendant’s response. . Defendant makes this request in good faith with no intention to unduly

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delay the proceedings. Counsel apologizes for the belated request, but made her request as soon

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as practicable, following her leave.

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Respectfully submitted,

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Dated: April 23, 2021

/s/ * Denise Haley
(*as authorized by email on April 23, 2021)
DENISE HALEY
Attorney for Plaintiff

Dated: April 23, 2021

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant

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JS for Extension of Time and Order

Case No. 1:18-cv-00089-SKO

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ORDER

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Pursuant to the parties’ above stipulation (Doc. 32), and for good cause shown,

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IT IS ORDERED that Defendant shall have an extension, up to and including May 21,

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2021, to respond to the Motion for Attorney’s Fees Pursuant to 42 U.S.C. § 406(b) (Doc. 29).

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Counsel for Plaintiff may file an optional reply brief by no later than June 4, 2021.

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IT IS SO ORDERED.
Dated:

April 26, 2021

/s/

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Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

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JS for Extension of Time and Order

Case No. 1:18-cv-00089-SKO

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