(SS)Zamilpa v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER TO EXTEND BRIEFING SCHEDULE. Order signed by Magistrate Judge Sheila K. Oberto on 9/16/2022. (Kusamura, W)

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PHILLIP A. TALBERT
United States Attorney
PETER K. THOMPSON
Acting Regional Chief Counsel, Region IX
Social Security Administration
CASPAR CHAN
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
Email: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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CELIA ZAMILPA,
Plaintiff,
v.
KILOLO KIJAKAZI,
Acting Commissioner of Social Security,
Defendant.

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Civil No. 1:21-cv-01702-SKO
STIPULATION AND ORDER TO EXTEND
BRIEFING SCHEDULE
(Doc. 12)

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The parties stipulate through counsel that Defendant, the Acting Commissioner of Social
Security (the “Commissioner”), shall have an extension of 14 days to respond to Plaintiff’s Motion for
Summary Judgment in this case. In support of this request, the Commissioner respectfully states as
follows:

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1.

September 15, 2022. This is Defendant’s first request for an extension of this deadline.

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2.

necessitating this Court to address the merits of this matter. Moreover, this brief extension would
conserve judicial time and resources should the Parties be able to resolve this matter.
3.

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Counsel for the Commissioner has consulted with Plaintiff’s counsel who advised that

he has no objections.

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Counsel for the Commissioner is consulting with his client about the defensibility of this

case. Counsel for the Commissioner believes that this short extension may resolve this matter without

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The Commissioner’s response to Plaintiff’s Motion for Summary Judgment is due

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This request is made in good faith and is not intended to delay the proceedings in this

matter.
WHEREFORE, Defendant requests until September 29, 2022, respond to Plaintiff’s Motion for
Summary Judgment.

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Date: September 16, 2022

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By:
/s/ Caspar Chan for Francisco Benavides*
FRANCISCO BENAVIDES
*Authorized by email on September 16, 2022
Attorneys for Plaintiff

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LAW OFFICES OF FRANCISCO BENAVIDES

Date: September 16, 2022

PHILIP A. TALBERT
United States Attorney
Eastern District of California

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By:
/s/ Caspar Chan
CASPAR CHAN
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Pursuant to the foregoing stipulation (Doc. 12), and for good cause shown,

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IT IS HEREBY ORDERED that Defendant shall have an extension, up to and including

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September 29, 2022, to file the response to Plaintiff’s opening brief. All other dates in the Scheduling
Order (Doc. 9) shall be extended accordingly.

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IT IS SO ORDERED.
Dated:

September 16, 2022

/s/ Sheila K. Oberto

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UNITED STATES MAGISTRATE JUDGE