(SS) Zavala v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 05/08/24 EXTENDING the deadline for Defendant to respond to 11 Motion for Summary Judgment to 06/05/24. (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
CASPAR CHAN, CSBN 294804
Special Assistant United States Attorney
Social Security Administration
6401 Security Boulevard
Baltimore, MD 21235
Telephone: [phone]
Facsimile: 415-744-0134
Email: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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SALVADOR ZAVALA,
Plaintiff,
v.
COMMISSIONER OF SOCIAL SECURITY,
Defendant.

) Civil No. 2:24-cv-00103-DMC
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) STIPULATION AND ORDER TO EXTEND
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) BRIEFING SCHEDULE
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The parties stipulate through counsel that Defendant, the Commissioner of Social Security (the
“Commissioner”), shall have an extension of 30 days to respond to Plaintiff’s Motion for Summary
Judgment in this case. In support of this request, the Commissioner respectfully states as follows:
1.

The Commissioner’s response to Plaintiff’s Motion for Summary Judgment is due May 6,

2024. Defendant has not previously received an extension of this deadline.
2.

Counsel for the Commissioner is in the process of discussing the defensibility of this

matter with his client. Counsel for the Commissioner believes that this short extension may resolve this
matter without necessitating this Court to address the merits of this matter. Moreover, this brief extension
would conserve judicial time and resources should the Parties be able to resolve this matter.
3.

Counsel for the Commissioner has consulted with Plaintiff’s counsel who advised that he

has no objections.
4.

This request is made in good faith and is not intended to unnecessarily delay the

proceedings in this matter.
WHEREFORE, Defendant requests until June 5, 2024, respond to Plaintiff’s Motion for
Summary Judgment.
Date: May 8, 2024

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KELLY, DUARTE, URSTOEGER & RUBLE, LLP
By:

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Date: May 8, 2024

PHILIP A. TALBERT
United States Attorney
Eastern District of California

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/s/ Caspar Chan for Jeffrey R. Duarte *
JEFFREY R. DUARTE
*Authorized by email on May 8, 2024
Attorneys for Plaintiff

By:

/s/ Caspar Chan
CASPAR CHAN
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED

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Dated: May 8, 2024

____________________________________
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE