Opinion
2:20-cv-02036-EFB
07-16-2021
SHELLY HALL Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner OF SOCIAL SECURITY, [1] Defendant.
WEEMS LAW OFFICES Robert C. Weems, Attorney for Plaintiff PHILLIP A. TALBERT Acting United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX SATHY OUM Special Assistant U.S. Attorney SATHY OUM, Special Assistant United States Attorney and Attorney for the Defendant
WEEMS LAW OFFICES Robert C. Weems, Attorney for Plaintiff
PHILLIP A. TALBERT Acting United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX SATHY OUM Special Assistant U.S. Attorney SATHY OUM, Special Assistant United States Attorney and Attorney for the Defendant
PROPOSED ORDER AND STIPULATION RE: MODIFICATION OF SCHEDULING ORDER
EDMUND F. BRENNAN U.S. MAGISTRATE JUDGE
Subject to the approval and any further orders of the Court, the parties, by and through 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 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 counsel when possible grounds for voluntary remand are identified, and develop, prioritize and brief issues for summary judgment consistent with the professional standards of the Court and without prejudice to the Plaintiff. By modification of the scheduling order in this and other pending matters, Plaintiffs counsel believes the fewer additional scheduling order modifications will be necessary, the risk of missed deadlines will be reduced, and the Court's effective and efficient administration of justice served. This request for this modification of the scheduling order is made in good faith, without dilatory motive and not for purposes of undue delay or to prejudice the interest of any party.
SO STIPULATED AND AGREED, July 14, 2021:
SO ORDERED.