(SS) Benephraim v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Chi Soo Kim on 03/06/25 EXTENDING the time to file Plaintiffs 12 Motion for Summary Judgment to 04/03/25. (Deputy Clerk KML)

1
2
3
4
5

Michelle J. Shvarts (SBN 235300)
DISABILITY ADVOCATES GROUP
18321 Ventura Blvd., Ste 355
Encino, CA 91356
TEL: [phone]
[e-mail]
Attorneys for Plaintiff, Riora Benephraim

6

UNITED STATES DISTRICT COURT

7

EASTERN DISTRICT OF CALIFORNIA

8
9
10

RIORA BENEPHRAIM
(SSN XXX-XX-3174),

11

Plaintiff,

12

vs.
COMMISSIONER OF SOCIAL
SECURITY,

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Defendant,

) Case No.: 2:24-cv-3310-CSK
)
)
)
) STIPULATION FOR EXTENSION OF
) BRIEFING SCHEDULE (FIRST
) REQUEST)
)
)
)
)
)
)
)

1

IT IS HEREBY STIPULATED, by and between the undersigned attorneys,

2

subject to the approval of the Court, that Plaintiff shall have a thirty day extension

3

to April 3, 2025, in which to deliver her the Motion for Summary Judgment. The

4

deadline for Defendant’s portion of the joint stipulation, the Plaintiff’s optional

5

reply shall also be extended according to the time allotted by the Court’s case

6

management order.

7

This is Plaintiff’s first request for an extension. This extension is requested

9

so that Plaintiff’s counsel of record can attend to a family emergency.
Respectfully submitted,

10

DISABILITY ADVOCATES GROUP

8

11
12

Dated: March 3, 2025

13
14

PHILLIP A. TALBERT

15

United States Attorney

16
17

By: /s/ Michelle J. Shvarts
MICHELLE J. SHVARTS
Attorney for Plaintiff

Dated: March 3, 2025

18
19
20

By: /s/ ___________________
Justin Martin
Special Assistant United States Attorney
Attorneys for Defendant
(as approved by email)

21
22

ORDER

23

Pursuant to the parties’ stipulation, IT IS SO ORDERED that, for good

24

cause shown, Plaintiff shall have an extension of time until April 3, 2025 to file her

25

motion for summary judgment.

26

Dated: 03/06/25

27
28

5, bene.3310.24