(SS) Rivera Alatorre v. Commissioner of Social Security

Filing 20

STIPULATION AND UNOPPOSED MOTION FOR AN EXTENSION OF TIME; ORDER. Order signed by Magistrate Judge Sheila K. Oberto on 7/3/2024. (Kusamura, W)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT United States Attorney MATHEW W. PILE, WSBN 32245 Associate General Counsel Office of Program Litigation, Office 7 Social Security Administration MICHAEL J. MULLEN, WSBN 54288 Special Assistant United States Attorney 6401 Security Boulevard Baltimore, Maryland 21235 Telephone: (206) 615-2748 E-Mail: michael.j.mullen@ssa.gov Attorneys for Defendant 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 Plaintiff, 13 14 15 16 17 ) ) ) ) ) ) ) ) ) ) ) ) JOSE JUAN RIVERA ALATORRE, vs. MARTIN O’MALLEY, Commissioner of Social Security, Defendant. Case No.: 1:23-cv-01686-SKO STIPULATION AND UNOPPOSED MOTION FOR AN EXTENSION OF TIME; ORDER 18 19 20 21 22 23 24 25 26 27 Pending the Court’s approval, IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of record, that the time for Defendant to respond to Plaintiff’s Motion for Summary Judgment be extended fourteen (14) days from July 3, 2024, up to and including July 17, 2024. This is the Defendant’s second request for an extension. The undersigned counsel for Defendant (“Counsel”) makes this request in good faith and for good cause. Upon review of the record and Opening Brief, Counsel prepared a memorandum to the client exploring settlement options in this matter. To allow time for the client to respond to the memorandum and negotiate a possible settlement with Plaintiff, or draft a responsive brief, if necessary, I am requesting a 14-day extension, until July 17, 2024, to file Defendant’s brief. 28 Stip. for Ext.; 1:23-cv-01686-SKO 1 1 Although Counsel has worked diligently on this matter and other assigned cases, this extension is 2 necessary. The parties further stipulate that the Court’s Scheduling Order shall be modified 3 4 accordingly. 5 6 7 Respectfully submitted, Dated: July 2, 2024 /s/ Dollly M. Trompeter* DOLLY M. TROMPETER Attorney for Plaintiff (*signature authorized via e-mail July 2, 2024) Dated: July 2, 2024 PHILLIP A. TALBERT United States Attorney MATHEW W. PILE Associate General Counsel Office of Program Litigation, Office 7 8 9 10 11 12 13 14 15 By: 16 17 /s/ Michael J. Mullen MICHAEL J. MULLEN Special Assistant U.S. Attorney Attorneys for Defendant 18 19 ORDER 20 Pursuant to the parties’ Stipulation (Doc. 19), and for good cause shown, 21 22 23 IT IS HEREBY ORDERED that Defendant shall have an extension of 14 days, to July 17, 2024, to file the Commissioner’s responsive brief. Plaintiff shall have up to and including July 31, 2024, to file an optional reply. 24 25 26 IT IS SO ORDERED. Dated: /s/ Sheila K. Oberto July 3, 2024 27 . UNITED STATES MAGISTRATE JUDGE 28 Stip. for Ext.; 1:23-cv-01686-SKO 2

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