(SS) Rodriguez v. Commissioner of Social Security

Filing 18

STIPULATION AND ORDER FOR A FIRST EXTENSION OF THIRTY DAYS FOR DEFENDANT'S OPPOSITION TO PLAINTIFF'S OPENING BRIEF signed by Magistrate Judge Gary S. Austin on 10/16/2020. (Gonzales, V)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
DANIEL P. TALBERT
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
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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RODOLFO RODRIGUEZ,

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Plaintiff,

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v.

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ANDREW SAUL,
Commissioner of Social Security,

No. 1:20-cv-00197-GSA
STIPULATION AND ORDER FOR A FIRST
EXTENSION OF THIRTY DAYS FOR
DEFENDANT’S OPPOSITION TO
PLAINTIFF’S OPENING BRIEF

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Defendant.
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The parties stipulate by counsel that Defendant shall have an extension of thirty days, until

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November 18, 2020, to file his opposition to Plaintiff’s opening brief. Good cause exists for this

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extension, as explained below.

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The originally assigned attorney for Defendant left the office, requiring reassignment to

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another attorney for filing. However, because of workload inconsistencies between the regional

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offices in the Office of General Counsel, an attorney in the Denver region has been assigned to

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brief this case, and the undersigned attorney for Defendant will review, revise, and file the

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opposition. Because this is a new procedure, the undersigned attorney for Defendant

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inadvertently delayed in informing the briefing attorney that Plaintiff had filed his opening brief,

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and the briefing attorney will require an additional thirty days from the current due date to

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complete the opposition to Plaintiff’s opening brief and share with the undersigned attorney for

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review and finalization before filing.

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For all these reasons, Defendant requests an extension of thirty days to file his opposition
to Plaintiff’s opening brief. Plaintiff’s counsel has no objection to this request.
Respectfully submitted October 15, 2020.

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DATED: October 15, 2020

/s/ Jacqueline Forslund
JACQUELINE FORSLUND
(as authorized by email)
Attorney for Plaintiff

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McGREGOR W. SCOTT
United States Attorney

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DATED: October 15, 2020

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By

s/ Daniel P. Talbert
DANIEL P. TALBERT
Special Assistant United States Attorney
Attorneys for Defendant

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IT IS SO ORDERED.
Dated:

October 16, 2020

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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