(SS) Clover v. Commissioner of Social Security

Filing 15

STIPULATION FOR AN EXTENSION OF TIME; ORDER signed by Magistrate Judge Gary S. Austin on 1/8/2025. Pursuant to the parties' stipulation, IT IS ORDERED that Defendant shall have an extension, up to and including February 14, 2025 to respond to Plaintiff's Opening Brief. (Deputy Clerk YV)

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PHILLIP TALBERT
United States Attorney
MATHEW W. PILE, WSBA No. 32245
Associate General Counsel
Office of Program Litigation, Office 7
Social Security Administration
MARY TSAI, CSBN 216963
Special Assistant United States Attorney
6401 Security Boulevard
Baltimore, MD 21235
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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FRESNO DIVISION
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) Case No.: 1:24-cv-00935-GSA
)
) STIPULATION FOR AN EXTENSION OF
Plaintiff,
) TIME; ORDER
)
vs.
)
)
COMMISSIONER OF SOCIAL SECURITY, )
)
)
Defendant.
)
)
JEREMY ROBERT CLOVER,

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Pending the Court’s approval, IT IS HEREBY STIPULATED, by and between the

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parties, through their respective counsel of record, that the time for Defendant to respond to

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Plaintiff’s Opening Brief be extended thirty (30) days from January 15, 2025, up to and

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including February 14, 2025. This is the parties’ second stipulation for an extension of the

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Court’s Scheduling Order, and Defendant’s first extension.

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This is Defendant’s first request for an extension, and it is made with good cause. This

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case was recently reassigned to undersigned counsel for Defendant, along with another brief,

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both of which are due in January 2025. Moreover, counsel already has six other briefs due in

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approximately the next month. Thus, Defendant requires an extension in this case, and may

Stip. for Ext.; 1:24-cv-00935-GSA

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require extensions in other cases, and requests this extension in good faith and with no intent to

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delay these proceedings unnecessarily.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,
Dated: January 8, 2025

/s/ Melissa Newel*
MELISSA NEWEL
Attorney for Plaintiff
*as authorized via e-mail on January 8, 2025

Dated: January 8, 2025

PHILLIP TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Office of Program Litigation, Office 7
Social Security Administration

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By:

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/s/ Mary Tsai
MARY TSAI
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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Pursuant to the parties’ stipulation, IT IS ORDERED that Defendant shall have an

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extension, up to and including February 14, 2025 to respond to Plaintiff’s Opening Brief.

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IT IS SO ORDERED.

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Dated:
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January 8, 2025

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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Stip. for Ext.; 1:24-cv-00935-GSA

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