Opinion
4:20-cv-07944-HSG
07-02-2021
JOSEPHINE PALAFOX, Plaintiff, v. ANDREW SAUL, Commissioner of Social Security, Defendant.
KATHERINE ROSE SIEGFRIED Attorney for Plaintiff STEPHANIE HINDS Acting United States Attorney TIMOTHY R. BOLIN Special Assistant United States Attorney Attorneys for Defendant
KATHERINE ROSE SIEGFRIED Attorney for Plaintiff
STEPHANIE HINDS Acting United States Attorney
TIMOTHY R. BOLIN Special Assistant United States Attorney Attorneys for Defendant
JOINT STIPULATION TO AN EXTENSION OF TIME; ORDER
HON. HAYWOOD S. GILLIAM, JR. UNITED STATES DISTRICT COURT JUDGE
STEPHANIE HINDS Acting United States Attorney DEBORAH L. STACHEL Regional Chief Counsel, Region IX TIMOTHY R. BOLIN (SBN 259511) Special Assistant United States Attorney Social Security Administration Office of the General Counsel 160 Spear St Ste 800 San Francisco, CA 94105 Telephone: (415) 977-8982 Facsimile: (415) 744-0134 Email: timothy.bolin@ssa.gov Attorneys for Defendant
The parties agree and stipulate to an extension of time for Defendant to respond to Plaintiffs motion for summary judgment, up to and including August 23, 2021. Defendant's counsel needs additional time due to pandemic-related work restrictions and increases in caseloads. This is his first request for an extension of time in which to respond to Plaintiffs motion for summary judgment.
In light of the global COVID-19 crisis, the SSA has taken the unprecedented step of suspending in-office services to the public. See https://www.ssa.gov/coronavirus/. The SSA is focusing on providing the most critical services by mail, phone, and online to those most in need. The SSA is also taking additional steps to protect its employees and help stop the spread of COVID-19, e.g., maximizing social distancing and significantly limiting employee access to SSA facilities.
Furthermore, the agency had more than 11, 100 new court cases waiting to be processed at the end of January 2021. Although CAR production is now at/above pre-pandemic levels, the No. of new complaints in district courts has also increased: in the first quarter of fiscal year 2021, the agency processed 5, 270 cases, compared to 4, 098 cases in the first quarter of fiscal year 2020 and 3, 970 in the first quarter of fiscal year 2019.
Given the volume of pending cases, Defendant asks the Court to extend his time for filing his response to Plaintiffs motion for summary until August 23, 2021. Defendant will file the response earlier if at all possible.
The undersigned affirms as follows: today I emailed opposing counsel, Katherine Rose Siefried, Esq., to ask whether she would agree to stipulate to this extension and allow me to sign it for her. She agreed to my requests. The parties stipulate in good faith, with no intent to prolong proceedings unduly.
ORDER
Pursuant to the foregoing joint stipulation to an extension of time, and for cause shown, THE COURT ORDERS that Defendant shall have until August 23, 2021, to file a response to Plaintiffs motion for summary judgment.