(SS) Stein v. Commissioner of Social Security

Filing 12

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 8/29/2024 EXTENDING the time allowed for Plaintiff to file her motion for summary judgment to 9/23/2024. (Mena-Sanchez, L)

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MARGARET LEHRKIND
SBCA # 314717
Lehrkind Law Office, P.C.
2625 Alcatraz Ave, # 208
Berkeley, CA 94705
Tel: [phone]
[e-mail]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA (SACRAMENTO)

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ANASTASIA JOY STEIN,
Plaintiff,
vs.

CASE NO.: 2:24-cv-01007-EFB
STIPULATION FOR EXTENSION OF TIME
TO FILE PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT; ORDER

COMMISSIONER OF SOCIAL SECURITY,
Defendant

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The parties, through their attorneys of record, hereby stipulate, subject to the Court's

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approval, to extend the time allowed for Plaintiff to file her motion for summary judgment to

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September 23, 2024.

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Good cause exists for this request. Plaintiff’s counsel has worked diligently to comply
with the Court’s deadlines in this case. However, Plaintiff’s counsel has several competing
deadlines in the first two weeks of September and personal obligations with her family and
requires an additional two weeks to prepare the motion for summary judgment in this case.
On August 29, 2024, Defendant’s counsel agreed to stipulate to Plaintiff’s request for an
extension of time.
Based on the foregoing, Plaintiff’s counsel requests that the court grant her request for an
extension of time.

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DATE: August 29, 2024

Respectfully submitted,

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By:

/s/ Margaret Lehrkind
Margaret Lehrkind
SBCA # 314717
2625 Alcatraz Ave, # 208
Berkeley, CA 94705
Tel: [phone]
[e-mail]

By:

/s/ Justin Lane Martin
Justin Lane Martin
Office of the General Counsel, SSA
Office of Program Litigation, Office 7
Social Security Administration
6401 Security Boulevard
Baltimore, MD 21235
510-970-4808
Email: [e-mail]

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IT IS SO ORDERED.
DATED: August 29, 2024.