(SS) Vang v. Commissioner of Social Security

Filing 17

STIPULATION FOR A SECOND EXTENSION OF TIME; ORDER signed by Magistrate Judge Gary S. Austin on 3/12/2025. Pursuant to the parties' stipulation, IT IS SO ORDERED that Defendant shall have an extension, up to and including March 28, 2025 to respond to Plaintiff's motion for summary judgment. (Deputy Clerk YV)

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MICHELE BECKWITH
Acting 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

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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-01292-KES-GSA
)
) STIPULATION FOR A SECOND
Plaintiff,
) EXTENSION OF TIME; ORDER
)
vs.
)
)
COMMISSIONER OF SOCIAL SECURITY, )
)
)
Defendant.
)
)
STEVEN VANG,

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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 motion for summary judgment be extended four (4) days from March 24, 2025, up to

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and including March 28, 2025. This is the parties’ second stipulation for an extension of the

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

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Defendant’s request is made with good cause. Undersigned counsel for Defendant has

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been out ill this week and must accompany her elderly father to last-minute medical

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appointments over the next week, including on March 13, 14, and 19, 2025. Moreover, counsel

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has other litigation deadlines due in the next two weeks. Thus, Defendant requires an extension

Stip. for Ext.; 1:24-cv-01292-KES-GSA

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in this case, and may require extensions in other cases, and requests this extension in good faith

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and with no intent to 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: March 12, 2025

/s/ Jonathan Omar Pena*
JONATHAN OMAR PENA
Attorney for Plaintiff
*as authorized via e-mail on March 12, 2025

Dated: March 12, 2025

MICHELE BECKWITH
Acting United States Attorney

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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

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Attorneys for Defendant

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ORDER

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

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extension, up to and including March 28, 2025 to respond to Plaintiff’s motion for summary

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judgment.

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IT IS SO ORDERED.
Dated:

March 12, 2025

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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Stip. for Ext.; 1:24-cv-01292-KES-GSA

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