(SS) Green v. Commissioner of Social Security

Filing 12

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 8/29/24 ORDERING that Defendant shall have an extension, up to and including 10/15/24, to respond to Plaintiff's Brief and Plaintiff's optional reply brief will be EXTENDED to 10/29/24. (Salmeron, A)

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE, WSBA 32245
Associate General Counsel
Office of Program Litigation, Office 7
MICHELLE A. PAVELEK, CSBN No. 300642
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RAYMOND DANIEL GREEN,
Plaintiff,
vs.
MARTIN O’MALLEY,
Commissioner of Social Security,
Defendant.

) Case No.: 2:24-cv-01381-DMC
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME
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Pending the Court’s approval, IT IS HEREBY STIPULATED, by and between the
parties, through their respective counsel of record, that the time for Defendant to respond to
Plaintiff’s Motion for Summary Judgment be extended thirty-three (33) days from September 12,
2024, up to and including October 15, 2024. This is the Defendant’s first extension request.
Defendant requests this extension in order to review the record; evaluate the issues raised
in Plaintiff’s brief; determine whether options exist for settlement; and if not, to prepare
Defendant’s response to Plaintiff’s motion. Defendant’s counsel was recently assigned this case
along with several other cases, and now has five cases due in the week of September 12, 2024.
Defendant’s counsel will endeavor to complete these tasks as soon as possible. This request is

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made in good faith and with no intention to unduly delay the proceedings, and counsel

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apologizes for any inconvenience.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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LAW OFFICES OF FRANCESCO BENAVIDES

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Dated: August 29, 2024

/s/ Francesco Paulo Benavides*
(*as authorized via e-mail)
FRANCESCO PAULO BENAVIDES
Attorney for Plaintiff

Dated: August 29, 2024

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

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By:

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/s/ Michelle A. Pavelek
MICHELLE A. PAVELEK
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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

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extension, up to and including October 15, 2024, to respond to Plaintiff’s Brief and Plaintiff’s

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optional reply brief will be extended to October 29, 2024.

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Dated: August 29, 2024

____________________________________
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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