(SS) Aguilar v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Jeremy D. Peterson on 3/7/2025 ORDERING that Defendant shall have an extension, up to and including 4/28/2025, to respond to Plaintiff's Motion for Summary Judgment. Plaintiff's reply is now due 5/12/2025. (Deputy Clerk LMS)

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MICHELE BECKWITH
Acting United States Attorney
MATHEW W. PILE, WSBA No. 32245
Associate General Counsel
Office of Program Litigation, Office 7
MARY TSAI, CSBN 216963
Special Assistant United States Attorney
Office of Program Litigation, Office 7
Office of the General Counsel
Social Security Administration
6401 Security Boulevard
Baltimore, MD 21235
Telephone: [phone]
E-Mail: [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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SACRAMENTO DIVISION

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) Case No.: 2:24-cv-03238-WBS-JDP
)
) STIPULATION AND [PROPOSED] ORDER
Plaintiff,
) FOR AN EXTENSION OF TIME
)
vs.
)
COMMISSIONER OF SOCIAL SECURITY, )
)
)
Defendant.
)
)
)
JUAN RAMON AGUILAR,

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Pending the Court’s approval, the parties hereby stipulate that the time for Defendant to

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respond to Plaintiff’s Motion for Summary Judgment be extended thirty-five (35) days from

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March 24, 2025, up to and including April 28, 2025. Plaintiff’s reply would be due May 12,

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2025.

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This is Defendant’s first request for an extension, and it is made with good cause. This

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case was recently reassigned to undersigned counsel for Defendant and counsel already has

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another brief due that day and several other briefs due by late April, along with other litigation

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matters. Thus, Defendant requires an extension in this case, and may require extensions in other

Stip. for Ext.; 2:24-cv-03238-WBS-JDP

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cases, and requests this extension in good faith and with no intent to delay these proceedings

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

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accordingly.

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Respectfully submitted,
Dated: March 7, 2025

/s/ Barbara M. Rizzo*
(*as authorized via e-mail on March 4, 2025)
BARBARA M. RIZZO
Attorney for Plaintiff

Dated: March 7, 2025

MICHELE BECKWITH
Acting United States Attorney

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MATHEW W. PILE
Associate General Counsel
Office of Program Litigation, Office 7

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By:

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/s/ Mary Tsai
MARY TSAI
Special Assistant U.S. Attorney
Office of Program Litigation, Office 7

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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 April 28, 2025, to respond to Plaintiff’s Motion for Summary

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Judgment. Plaintiff’s reply is now due May 12, 2025.

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IT IS SO ORDERED.

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Dated:

March 7, 2025
JEREMY D. PETERSON
UNITED STATES MAGISTRATE JUDGE

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Stip. for Ext.; 2:24-cv-03238-WBS-JDP

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