(SS) Davis v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 11/26/24 EXTENDING time to 12/06/24 for Defendant to respond to Plaintiff's Motion for Summary Judgment. (Benson, A.)

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Office of Program Litigation, Office 7
Oscar Gonzalez de Llano
Special Assistant United States Attorney
Social Security Administration
Office of General Counsel
6401 Security Boulevard
Baltimore, MD 21235
Telephone: [phone]
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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VINCENT BERNARD DAVIS,

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Plaintiff,

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v.

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MARTIN O’MALLEY,
Commissioner of Social Security,

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No. 2:24-cv-01874-CKD
STIPULATED MOTION AND ORDER FOR
AN EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT

Defendant.

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IT IS HEREBY STIPULATED, by and between the parties through their respective

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counsel of record, with the Court’s approval, that Defendant’s time for responding to Plaintiff’s

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Motion for Summary Judgment be extended fourteen (14) days from November 22, 2024 to

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December 6, 2024. This is Defendant’s second request for an extension. Counsel for Plaintiff

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has no objection to Defendant’s request for an extension.

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Good cause exists for this request. Defendant respectfully requests this additional time
because Counsel for Defendant has and will be unable to devote the time required to complete its

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response. Counsel has multiple merit briefs currently due in district court cases within the next

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week. Counsel for Defendant was out of the office the past couple days providing care for his

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child that is out sick and Counsel will also be out of the office on November 26-29, 2024. Given

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competing workload requirements and pending travel an extension until December 6, 2024 will

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provide the opportunity for the undersigned Counsel for Defendant to prioritize completing the

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response to Plaintiff’s Motion for Summary Judgment. The undersigned Counsel apologizes to

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the Court and Plaintiff’s counsel for any inconvenience caused by this request and delay. All

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other dates in the Court’s Scheduling Order shall be extended accordingly.

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Respectfully submitted,

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PHILLIP A. TALBERT
United States Attorney

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DATE: November 22, 2024

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By: s/ Oscar Gonzalez de Llano
OSCAR GONZALEZ DE LLANO
Special Assistant United States Attorney
Attorneys for Defendant

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Respectfully submitted,

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Law Offices of Lawrence D. Rohlfing, Inc., CPC

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DATE: November 22, 2024

By:

s/ Steven Gilbert Rosales *
Steven Gilbert Rosales
(*as authorized by email)
Attorney for Plaintiff

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ORDER
IT IS ORDERED that Defendant’s stipulated motion for extension of time (ECF No. 14)
is GRANTED. Defendant shall have an extension, up to and including December 6, 2024, to
respond to Plaintiff’s Motion for Summary Judgment.
Dated: November 26, 2024

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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