(SS) Chavez Jr v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 11/18/2022 GRANTING 16 Stipulation for extension of time, up to and including 1/3/2023, to respond to Plaintiff's Motion for Summary Judgment. (Perdue, C.)

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1 2 3 4 5 6 7 8 PHILLIP A. TALBERT United States Attorney MATHEW W. PILE, WSBA 32245 Associate General Counsel Office of Program Litigation, Office 7 ELIZABETH LANDGRAF, CSBN 313184 Special Assistant United States Attorney Social Security Administration 160 Spear Street, Suite 800 San Francisco, CA 94105 Telephone: (510) 970-4828 Facsimile: (415) 744-0134 Elizabeth.Landgraf@ssa.gov Attorneys for Defendant 9 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 FRESNO DIVISION 13 14 15 16 17 18 19 CARLOS CHAVEZ, JR., Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, No. 2:22-cv-00490-DMC STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT Defendant. 20 21 22 23 24 25 26 27 28 The parties stipulate through counsel that Defendant, the Acting Commissioner of Social Security (the “Commissioner”), shall have a first extension of 47 days to respond to Plaintiff’s Motion for Summary Judgment (“Motion”) (ECF No. 14), extending the date on which Defendant’s response is due from November 17, 2022, to January 3, 2023. Defendant needs more time to respond to Plaintiff’s Motion because the undersigned attorney for Defendant currently has seven briefs due over the two weeks, including Defendant’s Opposition in this case, and a total of nine district court briefs due during the month of December. 1 In addition, the undersigned attorney has recently experienced a health issue requiring several 2 medical appointments during the month of November, including a lengthy emergency room visit. 3 This unexpected health issue has caused the attorney for Defendant to unexpectedly need to take 4 leave from work. Accordingly, the Commissioner respectfully requests an extension of 45 days, 5 until January 3, 2023, to respond to Plaintiff’s Motion. 6 The attorney for Defendant sincerely apologizes for any inconvenience to the Court, 7 Plaintiff, and opposing counsel. This request is made in good faith and is not intended to delay the 8 proceedings in this matter. 9 10 11 Respectfully submitted, DATE: November 15, 2022 /s/ Jody Marie Peterson JODY MARIE PETERSON Attorney for Plaintiff (as approved via email) 12 13 PHILLIP A. TALBERT United States Attorney MATHEW W. PILE Associate General Counsel Social Security Administration 14 15 16 17 DATE: November 15, 2022 18 19 20 21 22 23 24 By /s/ Elizabeth Landgraf ELIZABETH LANDGRAF Special Assistant United States Attorney Attorneys for Defendant ORDER Pursuant to the parties’ stipulation, IT IS SO ORDERED that Defendant shall have an extension, up to and including January 3, 2023, to respond to Plaintiff’s Motion for Summary Judgment. Dated: November 18, 2022 ____________________________________ DENNIS M. COTA UNITED STATES MAGISTRATE JUDGE 25 26 27 28 2:22-cv-00490-DMC 2

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