(SS) Rania v. Commissioner of Social Security
Filing
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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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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
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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RICHARD RANIA,
Plaintiff,
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v.
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ANDREW SAUL,
Commissioner of Social Security,
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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
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counsel, subject to the approval of the Court, that Defendant shall have an extension of 30 days to
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file his cross-motion for summary judgment, until July 8, 2021.
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Because of extensions related to the COVID-19 pandemic and delayed production of
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certified administrative records throughout the country, the Social Security Administration has
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workload imbalances between various regions, requiring attorneys to provide assistance on cases
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in other regions. Currently the workload in the United States District Courts for the Eastern and
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Western Districts of Missouri is overwhelming the attorneys primarily responsible for briefing
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cases in those jurisdictions, even after obtaining multiple extensions. Therefore, other attorneys
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have received reassignments from those districts that require immediate attention, with no further
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extensions possible in many of those cases. The attorney responsible for briefing this case is one
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of the attorneys who has received reassignment of urgent cases from those districts.
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Because Defendant has not sought or received an extension for this brief, Defendant
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requests a first extension of thirty days, with a new due date of July 8, 2021. This extension
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would allow the Social Security Administration to balance its currently uneven workloads, give
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attention to the longest-pending cases, and give complete and appropriate consideration to
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briefing this case.
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Respectfully submitted June 1, 2021.
DATED: June 1, 2021
/s/ David Chermol
DAVID CHERMOL
(as authorized by email)
Attorney for Plaintiff
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PHILLIP A. TALBERT
Acting United States Attorney
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DATED: June 1, 2021
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s/ Daniel P. Talbert
DANIEL P. TALBERT
Special Assistant United States Attorney
Attorneys for Defendant
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By
ORDER
Pursuant to stipulation, it is so ordered.
Dated: June 4, 2021
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
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