(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)

Case 2:22-cv-01337-DMC Document 15 Filed 01/17/23 Page 1 of 2
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Jared Walker (SB#269029)
P.O. Box 1777
Orangevale, CA 95662
T: [phone]
F: [phone]
[e-mail]
Attorney for Plaintiff,
KATINA KONTOKANIS

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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KATINA KONTOKANIS,

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Plaintiff,

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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.

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IT IS STIPULATED, by and between the parties, through their respective counsel of record,

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that the time for Plaintiff to file her motion for summary judgment be extended an additional 30

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days from the existing deadline such that Plaintiff’s new deadline, with the Court’s approval, will

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be February 16, 2023. Defendant’s response to Plaintiff’s motion for summary judgment will be

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due on or before April 3, 2023. This is Plaintiff’s second request for an extension of time and is

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sought based on her counsel needing more time than anticipated to prepare Plaintiff’s motion, as

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well as to meet other conflicting deadlines in unrelated matters undersigned is solely responsible

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for. Plaintiff’s counsel apologizes for the inconvenience this request imposes but is unable to meet

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the current briefing schedule in this case due to overlapping motion filing deadlines in other social

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security disability cases with lengthy administrative records, and recent out of town travel associated

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with a family illness. With the Court’s approval, the parties further stipulate that all other dates in

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the Court’s Scheduling Order be extended accordingly alongside Plaintiff’s extension.

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///
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
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Dated: January 13, 2023

Respectfully submitted,

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/s/ Jared Walker
Jared T. Walker,
Attorney for Plaintiff

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SO STIPULATED:

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PHILLIP A. TALBERT
United States Attorney

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Dated: January 13, 2023

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By:

/s/ *Sharon Lahey
(*authorized by email on 1/13/2013)
SHARON LAHEY
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED:

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Dated: January 17, 2023

____________________________________
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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-2STIPULATION FOR SECOND EXTENSION OF TIME
FOR PLAINTIFF TO FILE OPENING BRIEF