(SS) Kessler v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 11/09/23 EXTENDING the time up to and including 12/18/23, to respond to Plaintiff's Motion for Summary Judgment.(Licea Chavez, V)

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE, WSBN 32245
Associate General Counsel
Office of Program Litigation, Office 7
Social Security Administration
ZACHARY BERKOFF-CANE, WSBN 47988
Special Assistant United States Attorney
6401 Security Boulevard
Baltimore, Maryland 21235
Telephone: [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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LAURA MARIE KESSLER,

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Plaintiff,
vs.
KILOLO KIJAKAZI,
Acting Commissioner of Social Security,

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Defendant.

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) Case No. 2:23-cv-01416-AC
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) STIPULATION AND [PROPOSED] ORDER
) FOR AN EXTENSION OF TIME
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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 thirty (30) days from November 17,

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2023, up to and including December 18, 2023. This is the Defendant’s first request for an

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extension.

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Defendant requests this extension in order to further consider the administrative record in
light of the issue raised in Plaintiff’s motion. Counsel for Defendant has not been dilatory.

Stip. for Ext.; 2:23-cv-01416-AC

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Counsel for Defendant has another eight briefs due in the next thirty days and needs more time to

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review the record in this case.

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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: November 9, 2023

/s/ Francesco Paulo Benavides*
(*as authorized via e-mail on November 9, 2023)
FRANCESCO PAULO BENAVIDES
Attorney for Plaintiff

Dated: November 9, 2023

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

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By:

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/s/ Zachary Berkoff-Cane
ZACHARY BERKOFF-CANE
Special Assistant U.S. Attorney

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Attorneys for Defendant

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

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extension, up to and including December 18, 2023, to respond to Plaintiff’s Motion for Summary

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Judgment.

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DATED: November 9, 2023

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Stip. for Ext.; 2:23-cv-01416-AC

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