(SS) Gouveia v. Commissioner of Social Security

Filing 11

STIPULATION and ORDER signed by Magistrate Judge Jeremy D. Peterson on 02/06/2024 EXTENDING, up to and including 02/26/24, Defendant's time to respond to 7 Motion for Summary Judgment. (Licea Chavez, V)

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Office of Program Litigation, Office 7
JULIE A.K. CUMMINGS, SBN HI 10635
Special Assistant United States Attorney
Office of Program Litigation, Office 7
Office of the General Counsel
Social Security Administration
6401 Security Boulevard
Baltimore, MD 21235
Telephone: [phone]
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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MAX GOUVEIA,
Plaintiff,

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Civil No. 2:23-cv-01442-JDP

STIPULATION AND PROPOSED ORDER FOR
EXTENSION OF TIME TO FILE
DEFENDANT’S BRIEF

vs.
COMMISSIONER OF SOCIAL SECURITY,

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Defendant.

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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 (ECF No. 7) be extended thirty (30) days from

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January 26, 2024, up to and including February 26, 2024. This is the Defendant’s first request for
an extension.

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STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO FILE DEFENDANT’S
BRIEF
Page 1
Case No. 2:23-cv-01442-JDP

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As counsel for Defendant, I make this request in good faith and for good cause. I request

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this extension in order to further consider the 1881-page administrative record in light of the

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three issues raised in Plaintiff’s motion. Additionally, I have had several briefs due in recent days

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in multiple district courts. In the next month, I have eight more briefs due in various district

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courts of the Ninth Circuit, including this one, and an oral argument. Accordingly, I ask the

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Court for more time so that I can properly represent the Commissioner in this and my other

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matters.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.
DATED February 6, 2024
Respectfully submitted,

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PHILLIP A. TALBERT
United States Attorney

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MATHEW W. PILE
Associate General Counsel
Office of Program Litigation, Office 7

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By:

/s/ Julie A.K. Cummings
JULIE A.K. CUMMINGS

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Special Assistant United States Attorney
Office of Program Litigation, Office 7

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Attorneys for Defendant

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Law Office of Jared T. Walker, PC

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/s/ Jared Thomas Walker
JARED THOMAS WALKER
(by email authorization)
Attorney for Plaintiff

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STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO FILE DEFENDANT’S
BRIEF
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Case No. 2:23-cv-01442-JDP

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

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extension, up to and including February 26, 2024, to respond to Plaintiff’s Motion for Summary

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Judgment.

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IT IS SO ORDERED.

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Dated:
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February 6, 2024
JEREMY D. PETERSON
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO FILE DEFENDANT’S
BRIEF
Page 3
Case No. 2:23-cv-01442-JDP