(SS) Hammack v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER re UNOPPOSED MOTION FOR EXTENSION OF TIME. Order signed by Magistrate Judge Sheila K. Oberto on 10/23/2024. (Kusamura, W)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT United States Attorney MATHEW W. PILE Associate General Counsel Office of Program Litigation, Office 7 MARGARET BRANICK-ABILLA (CABN 223600) Special Assistant United States Attorney Office of Program Litigation, Office 7 Office of the General Counsel Social Security Administration 6401 Security Boulevard Baltimore, MD 21235 Telephone: (510) 970-4809 Email: Margaret.Branick-Abilla@ssa.gov 9 Attorneys for Defendant 10 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 12 13 STEPHANIE LOREE HAMMACK, Civil No. 1:24-cv-00755-SKO 14 Plaintiff, 15 16 17 18 STIPULATION AND UNOPPOSED MOTION FOR EXTENSION OF TIME; ORDER vs. COMMISSIONER OF SOCIAL SECURITY, (Doc. 14) Defendant. 19 20 IT IS HEREBY STIPULATED by and between the parties, through their undersigned 21 attorneys, with this Court’s approval, to extend the time by 33 days, from October 30, 2024 to 22 December 2, 2024, for Defendant to file his Cross-Motion for Summary Judgment. Plaintiff’s 23 optional reply shall be due within 14 days after the filing of the Commissioner’s Cross-Motion. 24 25 26 27 28 This is Defendant’s first request for an extension of time. Plaintiff does not oppose the requested extension. The undersigned counsel for the Commissioner respectfully submits that good cause exists for the requested extension. Due to ongoing staffing fluctuations and organizational changes, the undersigned counsel for the Commissioner has been tasked with additional duties including Stipulation; Order Page 1 Case No. 1:24-cv-00755-SKO 1 serving as a jurisdictional coordinator, reviewing other attorneys’ work, training and mentoring 2 new attorneys, and handling more cases, including the instant case, which was recently reassigned 3 to her. The undersigned counsel for the Commissioner is also scheduled to be out of the office for 4 two weeks from late October into November. As a result, and despite diligent efforts to comply 5 with this Court’s Scheduling Order, the Commissioner needs an extension in the instant case to 6 review the administrative record, consider the issues that Plaintiff has raised, confer with his 7 client as necessary, and prepare the Commissioner’s Cross-Motion. Respectfully submitted, 8 9 Dated: October 22, 2024 LAW OFFICES OF LAWRENCE D. ROHLFING 10 By: /s/ Steven G. Rosales* STEVEN G. ROSALES Attorneys for Plaintiff [*As authorized by e-mail on Oct. 22, 2024] 12 13 14 Dated: October 23, 2024 PHILLIP A. TALBERT United States Attorney MATHEW W. PILE Associate General Counsel Office of Program Litigation, Office 7 15 16 17 By: 18 19 /s/ Margaret Branick-Abilla MARGARET BRANICK-ABILLA Special Assistant United States Attorney Attorneys for Defendant 20 21 ORDER 22 Pursuant to the parties’ stipulation and unopposed motion (Doc. 14), IT IS ORDERED that 23 the Commissioner’s Cross-Motion for Summary Judgment shall be due on December 2, 2024, and 24 Plaintiff’s optional reply shall be due within 14 days after the filing of the Commissioner’s Cross- 25 Motion. 26 27 IT IS SO ORDERED. Dated: 28 /s/ Sheila K. Oberto October 23, 2024 . UNITED STATES MAGISTRATE JUDGE Stipulation; Order Page 2 Case No. 1:24-cv-00755-SKO 1 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation; Order Page 3 Case No. 1:24-cv-00755-SKO

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