(SS) Wescott v. Commissioner of Social Security

Filing 18

STIPULATION AND ORDER for Extension of Time Nunc Pro Tunc, signed by Magistrate Judge Barbara A. McAuliffe on 11/18/2022. ( Responses due by 12/7/2022)(Martin-Gill, S)

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1 2 3 4 5 6 7 8 9 PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration SHARON LAHEY Special Assistant United States Attorney Social Security Administration 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (510) 970-4827 Email: sharon.lahey@ssa.gov Attorneys for DEFENDANT 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 FRESNO DIVISION 13 14 KAREN P. WESCOTT, 15 Plaintiff, 16 17 18 19 vs. KILOLO KIJAKAZI, Acting Commissioner Of Social Security, Defendant. 20 21 ) ) ) ) ) ) ) ) ) ) ) CIVIL NO. 1:21-cv-01323-BAM STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME NUNC PRO TUNC IT IS HEREBY STIPULATED, by and between Karen P. Wescott (“Plaintiff”) and Kilolo 22 Kijakazi, Acting Commissioner of Social Security (“Defendant”) (collectively, the “Parties”), by and 23 through their respective counsel of record that the time for Defendant to respond to Plaintiff’s Motion 24 for Summary Judgment (ECF No. 15) be extended by 30 days. The deadline was November 2, 2022, 25 and the new deadline would be December 7, 2022. This is the second extension of time requested in the 26 above-captioned matter and the first extension of time requested concerning Defendant’s response to 27 Plaintiff’s Motion for Summary Judgment. The Parties respectfully request this additional time because 28 it has recently come to the undersigned defense counsel’s attention that Defendant’s response is pastSTIPULATION AND PROPOSED ORDER CASE NO.: 1:21-cv-01323-BAM 1 2 3 4 due, however, the attorney responsible for briefing this case, Marla Letellier, Esq., is unexpectedly out of the office on leave. Defense counsel apologizes to the Court and Plaintiff for the timing of this request and attendant inconvenience. The Parties respectfully request that all other deadlines be modified accordingly. 5 6 Date: November 18, 2022 LOTT LAW OFFICES 7 By: /s/ Shellie Lott* SHELLIE LOTT (*Authorized by e-mail on November 18, 2022) Attorneys for Plaintiff 8 9 10 11 Date: November 18, 2022 12 PHILLIP A. TALBERT United States Attorney 13 By: /s/ Sharon Lahey SHARON LAHEY Special Assistant United States Attorney 14 15 16 17 ORDER 18 19 Pursuant to stipulation, and good cause appearing, Defendant’s request for an extension of time 20 to respond to Plaintiff’s Motion for Summary Judgment is GRANTED nunc pro tunc. Defendant shall 21 file a response to Plaintiff’s Motion for Summary Judgment on or before December 7, 2022. All other 22 deadlines in the Court’s Scheduling Order are modified accordingly. 23 IT IS SO ORDERED. 24 25 Dated: November 18, 2022 /s/ Barbara A. McAuliffe _ UNITED STATES MAGISTRATE JUDGE 26 27 28 STIPULATION AND PROPOSED ORDER CASE NO.: 1:21-cv-01323-BAM

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