(SS) Kelley v. Commissioner of Social Security

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ERIC GRANT
Acting United States Attorney
MATHEW W. PILE, WSBN 32245
Head of Program Litigation 1
Social Security Administration
MARLA K. LETELLIER, CA 234969
Special Assistant United States Attorney
6401 Security Boulevard
Baltimore, Maryland 21235
Telephone: (510) 970-4814
E-Mail: Marla.Letellier@ssa.gov
Attorneys for Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
CLYDE MARION KELLEY,
Plaintiff,
vs.
COMMISSIONER OF SOCIAL SECURITY,
Defendant.
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Case No.: 2:25-cv-01993-CKD
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME
Pending the Court’s approval, the time for Defendant to file her Motion for Summary
Judgment is extended thirty-five (35) days from December 3, 2025, up to and including January
7, 2026. This is the Defendant’s first request for an extension on the deadline to file his Motion
for Summary Judgment.
After being recently assigned this case, Counsel for Defendant respectfully requests this
extension in order to adequately evaluate the issues presented. Counsel requests a 35-day
extension due to the backlog of work created by the extended lapse in appropriations as well as
planned leave during the holidays. Defendant appreciates Plaintiff’s counsel’s professional
courtesy and apologizes to the Court for the inconvenience.
Accordingly, the parties hereby stipulate that Defendant’s Motion for Summary

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Judgment be due on January 7, 2025. The parties further stipulate that the Court’s Scheduling
Order shall be modified accordingly.
Respectfully submitted,
Dated: December 2, 2025 	ERIC GRANT
United States Attorney
By 	/s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant U.S. Attorney
Attorneys for Defendant
Dated: December 2, 2025 	GERRARD LAW OFFICES
By 	/s/ Josephine M. Gerard*
(*as authorized via e-mail on December 2, 2025)
JOSEPHINE M. GERARD
Attorney for Plaintiff
ORDER
Pursuant to the parties’ stipulation, IT IS SO ORDERED that Defendant shall have an
extension, up to and including January 7, 2026, to file his Motion for Summary Judgment.
Dated: December 5, 2025
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE