(SS) Masoud v. Commissioner of Social Security

Filing 15

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.)

Download PDF
1 2 3 4 5 6 7 8 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 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 FRESNO DIVISION 12 13 MOHAMMAD AHMAD MASOUD, 14 Plaintiff, 15 v. 16 17 18 ANDREW SAUL, Commissioner of Social Security, Defendant. 19 20 21 22 23 24 25 26 27 28 ) Case No.: 1:19-cv-00127-EPG ) ) STIPULATION AND ORDER TO ) EXTEND BRIEFING SCHEDULE ) ) ) ) ) ) ) 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 -1- 1 Security case pending before the Ninth Circuit; drafting briefs in Social Security cases before the 2 district courts within the Ninth Circuit; negotiating (or litigating) attorney fee matters pursuant to 3 the Equal Access to Justice Act before the district courts within the Ninth Circuit; defending the 4 Social Security Administration (agency) in personnel litigation pending before the Merit Systems 5 Protection Board; assisting with the training of a newly hired attorney in the agency’s Office of 6 the General Counsel, Region IX; and handling an arbitration involving the agency and one of the 7 agency’s collective bargaining units. 8 9 Counsel for Defendant apologizes to Plaintiff and the Court for any inconvenience caused by this delay. 10 11 Respectfully submitted, 12 13 Date: October 8, 2019 LAW OFFICES OF STUART T. BARASCH By: 14 15 16 17 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 18 19 20 21 22 By: /s/ Asim H. Modi ASIM H. MODI Special Assistant United States Attorney Attorneys for Defendant 23 24 25 26 27 28 -2- 1 Upon review of the parties’ stipulation, IT IS ORDERED that Defendant shall have until 2 November 12, 2019, to file a responsive brief to Plaintiff’s opening brief. All other deadlines in 3 the Court’s Scheduling Order (ECF No. 6.) shall be extended accordingly. 4 5 IT IS SO ORDERED. 6 Dated: 7 October 8, 2019 /s/ UNITED STATES MAGISTRATE JUDGE 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3-

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?