(SS) Rania v. Commissioner of Social Security

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 6/4/21 ORDERING that Defendant shall have an extension of 30 days to file his cross-motion for summary judgment, until July 8, 2021. (Kaminski, H)

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1 2 3 4 5 6 7 PHILLIP A. TALBERT Acting 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: (510) 970-4860 Facsimile: (415) 744-0134 Attorneys for Defendant 8 9 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 RICHARD RANIA, Plaintiff, 15 16 v. 17 ANDREW SAUL, Commissioner of Social Security, 18 19 20 No. 2:20-cv-01541-MCE-CKD STIPULATION AND ORDER FOR EXTENSION TO FILE MOTION FOR SUMMARY JUDGMENT Defendant. IT IS HEREBY STIPULATED by and between the parties through their undersigned 21 counsel, subject to the approval of the Court, that Defendant shall have an extension of 30 days to 22 file his cross-motion for summary judgment, until July 8, 2021. 23 Because of extensions related to the COVID-19 pandemic and delayed production of 24 certified administrative records throughout the country, the Social Security Administration has 25 workload imbalances between various regions, requiring attorneys to provide assistance on cases 26 in other regions. Currently the workload in the United States District Courts for the Eastern and 27 Western Districts of Missouri is overwhelming the attorneys primarily responsible for briefing 28 cases in those jurisdictions, even after obtaining multiple extensions. Therefore, other attorneys 1 have received reassignments from those districts that require immediate attention, with no further 2 extensions possible in many of those cases. The attorney responsible for briefing this case is one 3 of the attorneys who has received reassignment of urgent cases from those districts. 4 Because Defendant has not sought or received an extension for this brief, Defendant 5 requests a first extension of thirty days, with a new due date of July 8, 2021. This extension 6 would allow the Social Security Administration to balance its currently uneven workloads, give 7 attention to the longest-pending cases, and give complete and appropriate consideration to 8 briefing this case. 9 10 11 Respectfully submitted June 1, 2021. DATED: June 1, 2021 /s/ David Chermol DAVID CHERMOL (as authorized by email) Attorney for Plaintiff 12 13 PHILLIP A. TALBERT Acting United States Attorney 14 15 DATED: June 1, 2021 16 17 20 21 22 23 s/ Daniel P. Talbert DANIEL P. TALBERT Special Assistant United States Attorney Attorneys for Defendant 18 19 By ORDER Pursuant to stipulation, it is so ordered. Dated: June 4, 2021 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 2

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