Ner v. O'Malley

Filing 7

Order by Magistrate Judge Lisa J. Cisneros granting 6 Stipulation for an extension of time.(bns, COURT STAFF) (Filed on 6/5/2024)

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ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
MATHEW W. PILE (WSBA 32245)
Associate General Counsel
Office of Program Litigation, Office 7
ERIN HIGHLAND (GA Bar No. 153550)
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]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Plaintiff,

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vs.

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) Case No. 3:24-cv-2086-LJC
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME
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MARIA NER,

MARTIN O’MALLEY,
Commissioner of Social Security,
Defendant.

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IT IS HEREBY STIPULATED, by and between the parties through their respective
counsel of record, with the Court’s approval, that Defendant shall have a 30-day extension of
time, from June 7, 2024, to July 8, 2024, for Defendant to respond to Plaintiff’s Complaint (Dkt.
No. 1).
This is Defendant’s first request for an extension of time and good cause exists for this
extension. In accordance with 42 U.S.C. § 405(g), the Commissioner files a certified copy of the
transcript of the administrative record (CAR), including the evidence upon which the findings
Stip. to Extend Time & Order

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and decisions complained of are based. Our office has been informed by the client agency, which
is the Social Security Administration, Office of Appellate Operations, that the transcript is not
yet ready. The client agency therefore needs more time to prepare an administrative record for
the Court’s review.
Defendant’s counsel will endeavor to complete these tasks as soon as possible. This
request is made in good faith and with no intention to unduly delay the proceedings, and counsel
apologizes for any inconvenience.
Plaintiff does not oppose Defendant’s request for an extension of time.

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Respectfully submitted,
Dated: June 4, 2024

/s/ Francesco Benavides
(*as authorized via email on 6/4/24)
Attorney for Plaintiff

Dated: June 4, 2024

ISMAIL J. RAMSEY
United States Attorney

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By:

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/s/ Erin Highland
ERIN HIGHLAND
Special Assistant U.S. Attorney
Office of Program Litigation, Office 7

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Attorneys for Defendant

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In accordance with Civil Local Rule 5-1(i)(3), I, Erin Highland, attest that I have
obtained concurrence in the filing of this document from all other signatories listed here.

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.
Dated: June 5, 2024

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Stip. to Extend Time & Order

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THE HONORABLE LISA J. CISNEROS
United States Magistrate Judge

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