(SS) Thompson v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 11/25/24 EXTENDING time to 11/27/2024 to respond to 12 Motion for Summary Judgment. (Licea Chavez, V)

1
2
3
4
5
6
7
8

PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE, WSBN 32245
Associate General Counsel
Office of Program Litigation, Office 7
Social Security Administration
LILLIAN J. LEE, NY 5449764
Special Assistant United States Attorney
6401 Security Boulevard
Baltimore, Maryland 21235
Telephone: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11
12
13
14
15
16
17

) Case No. 2:24-CV-00793-DMC
)
) STIPULATION AND ORDER FOR AN
Plaintiff,
) EXTENSION OF TIME
)
vs.
)
)
)
COMMISSIONER OF SOCIAL SECURITY, )
)
)
Defendant.
)
MARINA THOMPSON,

18
19

Pending the Court’s approval, IT IS HEREBY STIPULATED, by and between the parties,

20

through their respective counsel of record, that the time for Defendant to respond to Plaintiff’s

21

Motion for Summary Judgment be extended seven (7) days from November 20, 2024, up to and

22

including November 27, 2024. The parties further stipulate that the Court’s Scheduling Order (ECF

23

No. 3) shall be modified accordingly.

24

This is the Defendant’s second request for an extension. Defendant respectfully requests

25

this extension to allow sufficient time to complete the Commissioner’s brief. Defendant’s counsel

26

has been out of the office for the majority of last week and this week due to illness. Counsel has

27

been diligent in her work, and in the last four weeks, has completed five responsive briefs. In

28

///

Stip. for Ext.; 2:24-CV-00793-DMC

1

1

addition to this case, counsel has six upcoming responsive briefs in the next four weeks.

2
3
4
5

Respectfully submitted,
Dated: November 20, 2024

By: /s/ Jesse S. Kaplan*
(*as authorized via e-mail on November 20, 2024)
JESSE S. KAPLAN
Attorney for Plaintiff

Dated: November 20, 2024

PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Social Security Administration

6
7
8
9
10
By:

11
12
13

/s/ Lillian J. Lee
LILLIAN J. LEE
Special Assistant U.S. Attorney
Attorneys for Defendant

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Stip. for Ext.; 2:24-CV-00793-DMC

2

ORDER

1
2

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

3

extension, up to and including November 27, 2024, to respond to Plaintiff’s Motion for Summary

4

Judgment.

5
6

Dated: November 25, 2024

____________________________________
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Stip. for Ext.; 2:24-CV-00793-DMC

3