(SS) Kontokanis v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 01/17/23 EXTENDING time for plaintiff to file their Motion for Summary Judgment to 2/16/2023 with defendant's Response due by 4/3/2023. (Licea Chavez, V)

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Case 2:22-cv-01337-DMC Document 15 Filed 01/17/23 Page 1 of 2 1 2 3 4 5 6 Jared Walker (SB#269029) P.O. Box 1777 Orangevale, CA 95662 T: (916) 476-5044 F: (916) 476-5064 jared@jwalker.law Attorney for Plaintiff, KATINA KONTOKANIS 7 IN THE UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 KATINA KONTOKANIS, 10 Plaintiff, 11 12 13 v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Case No.: 2:22-cv-01337-DMC STIPULATION FOR SECOND EXTENSION OF TIME FOR PLAINTIFF TO FILE OPENING BRIEF Defendant. 14 15 16 IT IS STIPULATED, by and between the parties, through their respective counsel of record, 17 that the time for Plaintiff to file her motion for summary judgment be extended an additional 30 18 days from the existing deadline such that Plaintiff’s new deadline, with the Court’s approval, will 19 be February 16, 2023. Defendant’s response to Plaintiff’s motion for summary judgment will be 20 due on or before April 3, 2023. This is Plaintiff’s second request for an extension of time and is 21 sought based on her counsel needing more time than anticipated to prepare Plaintiff’s motion, as 22 well as to meet other conflicting deadlines in unrelated matters undersigned is solely responsible 23 for. Plaintiff’s counsel apologizes for the inconvenience this request imposes but is unable to meet 24 the current briefing schedule in this case due to overlapping motion filing deadlines in other social 25 security disability cases with lengthy administrative records, and recent out of town travel associated 26 with a family illness. With the Court’s approval, the parties further stipulate that all other dates in 27 the Court’s Scheduling Order be extended accordingly alongside Plaintiff’s extension. 28 /// STIPULATION FOR SECONOD EXTENSION OF TIME FOR PLAINTIFF TO FILE OPENING BRIEF Case 2:22-cv-01337-DMC Document 15 Filed 01/17/23 Page 2 of 2 1 Dated: January 13, 2023 Respectfully submitted, 2 /s/ Jared Walker Jared T. Walker, Attorney for Plaintiff 3 4 5 SO STIPULATED: 6 PHILLIP A. TALBERT United States Attorney 7 8 9 Dated: January 13, 2023 10 11 By: /s/ *Sharon Lahey (*authorized by email on 1/13/2013) SHARON LAHEY Special Assistant United States Attorney Attorneys for Defendant 12 13 ORDER 14 15 APPROVED AND SO ORDERED: 16 17 18 19 20 Dated: January 17, 2023 ____________________________________ DENNIS M. COTA UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26 27 28 -2STIPULATION FOR SECOND EXTENSION OF TIME FOR PLAINTIFF TO FILE OPENING BRIEF

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