(SS)Rangel v. Commissioner of Social Security

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 07/08/2024 EXTENDING the Deadline for the Commissioner to respond to 11 Motion for Summary Judgment to 08/07/2024. (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 CASPAR CHAN, CSBN 294804 Special Assistant United States Attorney Social Security Administration 6401 Security Boulevard Baltimore, MD 21235 Telephone: 510-970-4810 Facsimile: 415-744-0134 Email: Caspar.Chan@ssa.gov Attorneys for Defendant UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MARIA RANGEL, Plaintiff, v. COMMISSIONER OF SOCIAL SECURITY, Defendant. ) Civil No. 2:24-cv-00782-CKD ) ) STIPULATION AND ORDER TO EXTEND ) ) BRIEFING SCHEDULE ) ) ) ) ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 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 July 8, 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 August 7, 2024, respond to Plaintiff’s Motion for Summary Judgment. Date: July 8, 2024 18 By: 19 20 21 22 Date: July 8, 2024 23 24 LAW OFFICES OF FRANCESCO BENAVIDES 25 //// 26 //// 27 //// 28 //// /s/ Francesco Benavides* FRANCESCO BENAVIDES *Authorized by email on July 8, 2024 Attorneys for Plaintiff PHILIP A. TALBERT United States Attorney Eastern District of California 1 By: 2 3 /s/ Caspar Chan CASPAR CHAN Special Assistant United States Attorney Attorneys for Defendant 4 5 ORDER 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 APPROVED AND SO ORDERED. Dated: July 8, 2024 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE

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