(SS) Hall v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 7/16/2021 MODIFYING The Scheduling Order as follows: Plaintiffs time to move for Summary Judgment is EXTENDED from 7/15/2021 to 7/26/2021, with all other deadlines to follow as stated in the scheduling order. (Mena-Sanchez, L)

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1 2 3 Robert C. Weems (CA SBN 148156) WEEMS LAW OFFICES 526 3rd St., Ste. A-2 San Rafael, CA 94901 Ph: 415.881.7653 Fx: 866.610.1430 rcweems@weemslawoffices.com 4 5 Attorneys for Plaintiff, SHELLY HALL 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 SHELLY HALL 11 12 13 14 Plaintiff, v. Case 2:20-cv-02036-EFB PROPOSED ORDER AND STIPULATION RE: MODIFICATION OF SCHEDULING ORDER KILOLO KIJAKAZI, ACTING 1 COMMISSIONER OF SOCIAL SECURITY, 15 Defendant. 16 Subject to the approval and any further orders of the Court, the parties, by and through 17 18 19 20 21 counsel of record, stipulate and agree to Plaintiff’s time to move for summary judgment under the scheduling order be extended from JULY 15, 2021 to MONDAY, JULY 26, 2021, with all other deadlines to follow as stated in the scheduling order; and further agree that the modification is supported by good cause, will not unduly delay resolution and is not prejudicial to either party. The good cause supporting modification of the scheduling order includes that COVID-19’s 22 23 24 25 26 27 interruptions in the Social Security Administration’s operations effecting the filing of certified administrative transcripts has resulted in concentration of filing deadlines in Plaintiff’s counsel’s active Social Security cases in the Northern and Eastern Districts of California which has interfered with Plaintiff’s counsel able to fully analyze administrative transcripts, meet and confer with defense 1 Under Fed. R. Civ. P. 25(d) when public officer who is a party in an official capacity dies, resigns, or otherwise ceases to hold office; the officer's successor is automatically substituted as a party. On 28 Friday, July 9, 2021, Andrew Saul was terminated. Kilolo Kijakazi is Acting Commissioner. 1 STIPULATION «Case» 1 counsel when possible grounds for voluntary remand are identified, and develop, prioritize and brief 2 issues for summary judgment consistent with the professional standards of the Court and without 3 prejudice to the Plaintiff. By modification of the scheduling order in this and other pending matters, 4 Plaintiff’s counsel believes the fewer additional scheduling order modifications will be necessary, the 5 risk of missed deadlines will be reduced, and the Court’s effective and efficient administration of 6 justice served. This request for this modification of the scheduling order is made in good faith, 7 without dilatory motive and not for purposes of undue delay or to prejudice the interest of any party. 8 SO STIPULATED AND AGREED, July 14, 2021: 9 10 For Plaintiff: For Defendant: WEEMS LAW OFFICES PHILLIP A. TALBERT Acting United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX SATHY OUM Special Assistant U.S. Attorney 11 12 13 14 15 /s/Robert C. Weems /s/Sathy Oum By: Robert C. Weems, Attorney for Plaintiff SATHY OUM, Special Assistant United States Attorney and Attorney for the Defendant 16 17 18 SO ORDERED. DATED: July 16, 2021. EDMUND F. BRENNAN U.S. MAGISTRATE JUDGE 19 20 21 22 23 24 25 26 27 28 2 STIPULATION «Case»

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