(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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1 2 3 4 5 6 7 8 9 10 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: (415) 977-8928 Marla.Letellier@ssa.gov Attorneys for Defendant 11 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION 12 13 14 15 RHONDA JEAN CROCKER, Plaintiff, 16 17 18 19 Civil No. 2:23-cv-02132-DMC STIPULATION AND ORDER FOR AN EXTENSION OF TIME vs. COMMISSIONER OF SOCIAL SECURITY, Defendant. 20 21 22 23 24 25 26 27 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 Page 1 Case No. 2:23-cv-02132-DMC 1 diligence. In addition to this case, the undersigned is preparing the Commissioner’s response 2 briefs for multiple district court cases with concurrent deadlines. Plus, the undersigned is 3 assigned to train and review the briefing prepared by an attorney recently hired by this counsel’s 4 5 6 7 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 8 the issues raised in Plaintiff’s Opening Brief. This request is made in good faith and with no 9 intention to unduly delay the proceedings. Defendant appreciates Plaintiff’s counsel’s 10 11 12 13 14 15 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 16 17 18 /s/ Jacqueline A. Forslund DATED: May 30, 2024 19 20 21 22 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 24 By: /s/ Marla Latellier MARLA LATELLIER Special Assistant United States Attorney 25 Attorneys for Defendant 23 26 27 Stip. & Prop. Order Re Extension of Time Page 2 Case No. 2:23-cv-02132-DMC ORDER 1 2 3 4 5 6 7 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 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Stip. & Prop. Order Re Extension of Time Page 3 Case No. 2:23-cv-02132-DMC

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