(SS) Crocker v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 06/03/2024 GRANTING 16 Stipulation and Proposed Order and DIRECTING Defendant to file a response to 15 Motion for Summary Judgment by 07/05/2024. (Murphy, J)

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Office of Program Litigation, Office 7
MARLA K. LETELLIER
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]
[e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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RHONDA JEAN CROCKER,
Plaintiff,

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Civil No. 2:23-cv-02132-DMC
STIPULATION AND ORDER
FOR AN EXTENSION OF TIME

vs.
COMMISSIONER OF SOCIAL SECURITY,
Defendant.

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IT IS HEREBY STIPULATED by the parties, through their counsels, that Defendant, the
Commissioner of Social Security, shall have a 30-day extension of time, to July 5, 2024, of the
deadline to file Defendant’s Brief. This is Defendant’s first request for an extension of the time
to file its response to Plaintiff’s Motion for Summary Judgment.
There is good cause for this extension. Defendant respectfully requests this additional
time because Defendant’s counsel is experiencing an extremely heavy workload, despite due

Stip. & Prop. Order Re Extension of Time

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Case No. 2:23-cv-02132-DMC

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diligence. In addition to this case, the undersigned is preparing the Commissioner’s response

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briefs for multiple district court cases with concurrent deadlines. Plus, the undersigned is

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assigned to train and review the briefing prepared by an attorney recently hired by this counsel’s

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office. This case is being used as a case for such training. An additional thirty days would
provide the undersigned with the time to thoroughly review the newly-hired attorney’s draft brief
before filing. For this reason, Defendant’s counsel requires additional time to properly address

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the issues raised in Plaintiff’s Opening Brief. This request is made in good faith and with no

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intention to unduly delay the proceedings. Defendant appreciates Plaintiff’s counsel’s

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professional courtesy and apologizes to the Court for the inconvenience.
It is therefore requested that Defendant be granted an extension of time to respond to
Plaintiff’s Opening Brief, through and including July 5, 2024.
Respectfully submitted,
DATED: May 30, 2024

(*as authorized via e-mail on May 30, 2024)
JACQUELINE A. FORSLUND
Attorney for Plaintiff

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/s/ Jacqueline A. Forslund

DATED: May 30, 2024

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E. MARTIN ESTRADA
United States Attorney
DAVID M. HARRIS
Assistant United States Attorney
Chief, Civil Division
CEDINA M. KIM
Assistant United States Attorney
Senior Trial Attorney, Civil Division

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By: /s/ Marla Latellier
MARLA LATELLIER
Special Assistant United States Attorney

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Attorneys for Defendant

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Stip. & Prop. Order Re Extension of Time

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Case No. 2:23-cv-02132-DMC

ORDER

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Pursuant to the parties’ stipulation, IT IS SO ORDERED that Defendant shall have an
extension, up to and including July 5, 2024, to respond to Plaintiff’s Motion for Summary
Judgment.

Dated: June 3, 2024
_______________________________
_____
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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Stip. & Prop. Order Re Extension of Time

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Case No. 2:23-cv-02132-DMC