(SS) Chavez Jr v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 1/19/23 GRANTING plaintiff an extension up to and including 2/2/23, to respond to Defendant's Motion for Summary Judgment. (Kastilahn, A)

Case 2:22-cv-00490-DMC Document 20 Filed 01/19/23 Page 1 of 2

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JODY M. PETERSON (SBN 326074)
Attorney at Law
P. O. Box 7636
Chico, CA 95927
Telephone: [phone]
Attorney for Plaintiff
Carlos Chavez, Jr.
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CARLOS CHAVEZ, JR.,

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Plaintiff,
V.
COMMISSIONER OF
SOCIAL SECURITY,

Case No. 2:22-CV-00490-DMC
STIPULATION AND ORDER, ON
PLANTIFF’S REQUEST FOR
EXTENTION OF TIME TO FILE A
REPLY TO DEFENDANT’S MOTION
FOR SUMMARY JUDGMENT

Defendant,

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The parties stipulate through counsel that Plaintiff shall have a first extension of
15 days to file a reply in support of Plaintiff’s Motion for Summary Judgment and in opposition
to Defendant’s Motion for Summary Judgment (“Motion”) (ECF No. 15), extending the date on
which Plaintiff’s response is due from January 18, 2023, to February 2, 2023.
Plaintiff needs more time to respond to Defendant’s Motion because the undersigned
attorney for Plaintiff has returned to office after extenuating family/medical health issues and
upon her return on January 2, 2023, she had three emergency hearings, including three trial
briefs due for unrelated matters in the same two weeks in which the Defendant filed her Motion,
prompting a deadline to file Plaintiff’s reply brief by January 18, 2023.
The attorney for Plaintiff sincerely apologizes for any inconvenience to the Court,
Defendant and opposing counsel. This request is made in good faith and is not intended to delay
the proceedings in this matter. It was with utmost respect that consideration be given, as absent

Law Office of Jody M. Peterson P. O. Box 7636 Chico, CA 95927
Page 1
STIPULATION AND [PROPOSED] ORDER, ON PLANTIFF’S REQUEST FOR EXTENTION OF TIME TO FILE A REPLY TO
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

Case 2:22-cv-00490-DMC Document 20 Filed 01/19/23 Page 2 of 2

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those ex-parte hearings that Petitioner’s attorney was ordered to appear at, this further
complicated her ability to complete the reply brief as expected.

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Respectfully submitted,

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DATE: January 18, 2023

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/s/ Jody Marie Peterson
JODY MARIE PETERSON
Attorney for Plaintiff

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Social Security Administration

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DATE: January 18, 2023

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By /s/ Elizabeth Landgraf
ELIZABETH LANDGRAF
Special Assistant United States Attorney
Attorneys for Defendant
(as approved via email)
ORDER

Pursuant to the parties’ stipulation, IT IS SO ORDERED that Plaintiff shall
have an extension, up to and including February 2, 2023, to respond to Defendant’s Motion for
Summary Judgment.

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Dated: January 19, 2023
_____________________________
_______
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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Law Office of Jody M. Peterson P. O. Box 7636 Chico, CA 95927
Page 2
STIPULATION AND [PROPOSED] ORDER, ON PLANTIFF’S REQUEST FOR EXTENTION OF TIME TO FILE A REPLY TO
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT