(SS) Masoud v. Commissioner of Social Security
Filing
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Stipulation and Order to extend briefing schedule, signed by Magistrate Judge Erica P. Grosjean on 10/8/2019. (Filing Deadline: 11/12/2019) (Rosales, O.)
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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI, NYSBN 4692018
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: 415-977-8952
Facsimile: 415-744-0134
Email: asim.modi@ssa.gov
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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MOHAMMAD AHMAD MASOUD,
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Plaintiff,
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v.
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ANDREW SAUL,
Commissioner of Social Security,
Defendant.
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) Case No.: 1:19-cv-00127-EPG
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) STIPULATION AND ORDER TO
) EXTEND BRIEFING SCHEDULE
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to
extend Defendant’s time to file his response to Plaintiff’s opening brief with the Court by 30
days to November 12, 2019, and that all other scheduling dates set forth in the Court’s Case
Management Order shall be extended accordingly. This is Defendant’s first request for an
extension of time in this matter and he requests it in good faith and without any intent to prolong
proceedings unduly.
There is good cause for this extension request because counsel for Defendant is
responsible for performing a range of tasks that preclude drafting the Commissioner’s response
to Plaintiff’s opening brief by October 10, 2019, such as: drafting an answering brief in a Social
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Security case pending before the Ninth Circuit; drafting briefs in Social Security cases before the
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district courts within the Ninth Circuit; negotiating (or litigating) attorney fee matters pursuant to
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the Equal Access to Justice Act before the district courts within the Ninth Circuit; defending the
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Social Security Administration (agency) in personnel litigation pending before the Merit Systems
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Protection Board; assisting with the training of a newly hired attorney in the agency’s Office of
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the General Counsel, Region IX; and handling an arbitration involving the agency and one of the
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agency’s collective bargaining units.
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Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused
by this delay.
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Respectfully submitted,
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Date: October 8, 2019
LAW OFFICES OF STUART T. BARASCH
By:
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Date: October 8, 2019
/s/ Asim H. Modi for Stuart T. Barasch*
STUART T. BARASCH
*Authorized by email on October 8, 2019
Attorney for Plaintiff
McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
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By:
/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant
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Upon review of the parties’ stipulation, IT IS ORDERED that Defendant shall have until
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November 12, 2019, to file a responsive brief to Plaintiff’s opening brief. All other deadlines in
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the Court’s Scheduling Order (ECF No. 6.) shall be extended accordingly.
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IT IS SO ORDERED.
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Dated:
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October 8, 2019
/s/
UNITED STATES MAGISTRATE JUDGE
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