(SS) Rodriguez v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER FOR A SECOND EXTENSION OF THIRTY DAYS FOR DEFENDANT'S OPPOSITION TO PLAINTIFF'S OPENING BRIEF, signed by Magistrate Judge Gary S. Austin on 11/17/2020. Defendant is granted an additional thirty days to file his opposition to Plaintiff's opening brief, until December 18, 2020. (Apodaca, P)

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1 2 3 4 5 6 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: (415) 977-8995 Facsimile: (415) 744-0134 Attorneys for Defendant 7 8 9 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 FRESNO DIVISION 13 14 RODOLFO RODRIGUEZ, 15 Plaintiff, 16 v. 17 ANDREW SAUL, Commissioner of Social Security, No. 1:20-cv-00197-GSA STIPULATION AND ORDER FOR A SECOND EXTENSION OF THIRTY DAYS FOR DEFENDANT’S OPPOSITION TO PLAINTIFF’S OPENING BRIEF 18 Defendant. 19 20 The parties stipulate by counsel that Defendant shall have an extension of thirty days, until 21 December 18, 2020, to file his opposition to Plaintiff’s opening brief. Good cause exists for this 22 extension, as explained below. 23 The originally assigned attorney for Defendant left the office, requiring reassignment to 24 another attorney for filing. However, because of workload inconsistencies between the regional 25 offices in the Office of General Counsel, an attorney in the Denver region has been assigned to 26 brief this case, and the undersigned attorney for Defendant will review, revise, and file the 27 opposition. The attorney responsible for briefing this case has been ill and was out of the office 28 in recent weeks, precluding him from working on this brief; he anticipates being out of the office 1 throughout this week and next week, and will therefore require additional time to brief this case, 2 and for the undersigned attorney for Defendant to review and file that brief. The undersigned 3 attorney for Defendant is currently reviewing briefs for two new attorneys in his office this week 4 and preparing for an oral argument before the Ninth Circuit this week, and does not anticipate 5 being able to brief the case this week either. 6 7 8 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 November 16, 2020. 9 10 DATED: November 16, 2020 /s/ Jacqueline Forslund JACQUELINE FORSLUND (as authorized by email) Attorney for Plaintiff 11 12 McGREGOR W. SCOTT United States Attorney 13 14 DATED: November 16, 2020 15 16 By s/ Daniel P. Talbert DANIEL P. TALBERT Special Assistant United States Attorney Attorneys for Defendant 17 ORDER 18 19 20 21 Good cause appearing, Defendant is granted an additional thirty days to file his opposition to Plaintiff’s opening brief, until December 18, 2020. IT IS SO ORDERED. 22 23 Dated: November 17, 2020 /s/ Gary S. Austin UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 2

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