(SS) Valdez v. Commissioner of Social Security

Filing 10

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 6/26/2024 AMENDING Briefing Schedule deadlines as follow: Plaintiff's Motion for Summary Judgment due 7/24/2024; Defendant's Cross-Motion due 8/23/2024; Plaintiff's optional Reply due 9/6/2024. (Mendez Licea, O)

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1 2 3 4 5 6 Monica Perales Attorney at Law: 297739 12631 East Imperial Highway Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)868-5886 Fax: (562)868-8868 E-Mail: rohlfing.office@rohlfinglaw.com Attorneys for Plaintiff ARTHUR R. VALDEZ 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 ARTHUR R. VALDEZ Plaintiff, 13 v. 14 MARTIN O'MALLEY, Commissioner of Social Security, 15 16 Defendant. 17 ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:24-cv-00907-DMC STIPULATION TO EXTEND TIME TO FILE MOTION FOR SUMMARY JUDGMENT; ORDER (FIRST REQUEST) 18 TO THE COURT: 19 Plaintiff Arthur R. Valdez and Defendant Martin O'Malley, Commissioner 20 of Social Security, by and through their attorneys, stipulate, subject to this court’s 21 approval, to extend the time from June 19, 2024, to July 24, 2024, for Plaintiff to 22 file his Motion for Summary Judgment, with all other dates extended accordingly. 23 This is Plaintiff’s first request for an extension. This request is made at the request 24 of Plaintiff’s counsel to allow additional time to fully research the issues presented. 25 // 26 -1- 1 Counsel's autoimmune-compromised mother, for whom she is a caretaker, 2 has fallen ill due to a significant lupus flare, requiring additional medical care. 3 Consequently, counsel has had to take the last two weeks off to attend to her 4 mother's medical needs. 5 The parties request that the briefing schedule be modified as follows: 6 Plaintiff will file his Motion for Summary Judgment by July 24, 2024. Defendant 7 will file his Cross-Motion for Summary Judgment by August 23, 2024. Plaintiff 8 may file any optional reply within 14 days of the service of the Commissioner’s 9 Cross-Motion for Summary Judgment. The parties make this request in good faith 10 with no intention to unduly delay the proceedings. 11 DATE: June 18, 2024 LAW OFFICES OF LAWRENCE D. ROHLFING, INC., CPC 12 13 /s/ Monica Perales 1 BY: _________________________ Monica Perales Attorney for plaintiff Arthur R. Valdez 14 15 16 17 Respectfully submitted, DATE: June 18, 2024 18 19 20 PHILLIP TALBERT United States Attorney MATHEW W. PILE Associate General Counsel Social Security Administration 21 22 23 24 25 26 Counsel for the plaintiff attests that all other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 1 -2- 1 /s/ Justin L. Martin BY: ____________________________ Justin L. Martin Special Assistant United States Attorney Attorneys for defendant Martin O'Malley, Commissioner of Social Security |*authorized by e-mail| 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 ORDER Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY ORDERED that the briefing schedule is amended: Plaintiff’s Motion for Summary Judgment due: July 24, 2024; Defendant’s Cross-Motion due: August 23, 2024; and Plaintiff’s optional reply due: September 6, 2024. IT IS SO ORDERED Dated: June 26, 2024 _______________________________ _____ DENNIS M. COTA UNITED STATES MAGISTRATE JUDGE 18 19 20 21 22 23 24 25 26 -3- 1 2 3 4 5 6 7 8 9 10 CERTIFICATE OF SERVICE FOR CASE NUMBER 2:24-CV-00907-DMC I hereby certify that I electronically filed the foregoing with the Clerk of the Court for this court by using the CM/ECF system on June 18, 2024. I certify that all participants in the case are registered CM/ECF users and that service will be accomplished by the CM/ECF system. /s/ Monica Perales _______________________________ Monica Perales Attorneys for Plaintiff 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 -4-

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