(SS) Griffin v. Commissioner of Social Security

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
LANICE MARIE GRIFFIN,
Plaintiff,
v.
COMMISSIONER OF SOCIAL SECURITY,
Defendant.
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Civil No. 1:25-cv-00999-KES-BAM
STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S
COMPLAINT
The parties stipulate through counsel that Defendant, the Commissioner of Social Security (the
“Commissioner”), shall have an extension of time to respond to Plaintiff’s Complaint in this case. In
support of this request, the Commissioner respectfully states as follows:
1. Defendant’s response to Plaintiff’s Complaint is due November 12, 2025. Defendant has
previously extended this deadline once for 30 days.
2. At the end of the day on September 30, 2025, the appropriations that have been funding
the Department of Justice expired and appropriations to the Department lapsed. The same is true for most
Executive agencies, including federal defendant Social Security Administration (SSA). It is not clear
when funding will be restored by Congress.
ERIC GRANT
United States Attorney
MATHEW W. PILE, WSBN 32245
Head of Program Litigation 1
Oscar Gonzalez de Llano
Special Assistant United States Attorney
Social Security Administration
Program Litigation 1
Law & Policy
6401 Security Boulevard
Baltimore, MD 21235
Telephone: (510) 970-4818
Email: Oscar.Gonzalez@ssa.gov
Attorneys for Defendant
Case 1:25-cv-00999-KES-FJS Document 13 Filed 11/05/25 Page 1 of 3

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3. Absent an appropriation or continuing resolution, Department of Justice and SSA
attorneys are prohibited from working, even on a voluntary basis, except in very limited circumstances,
including “emergencies involving the safety of human life or the protection of property.” 31 U.S.C.
§ 1342. That exception is not deemed to include attorneys assigned to most civil cases at this time.
4. Given this situation Defendant requests an extension of 37 days to respond to Plaintiff’s
Complaint.
5. Counsel for the Commissioner has consulted with Plaintiff’s counsel who advised that
they have no objections.
6. This request is made in good faith and is not intended to delay the proceedings in this
matter.
WHEREFORE, Defendant requests until December 19, 2025, respond to Plaintiff’s Complaint.
Respectfully submitted,
Date: November 5, 2025 By: /s/ Jonathan Omar Pena
Jonathan Omar Pena
Pena and Bromberg, PC
Attorney for Plaintiff
(*as authorized by email)
Date: November 5, 2025 ERIC GRANT
United States Attorney
MATHEW W. PILE
Head of Program Litigation 1
By: /s/ Oscar Gonzalez de Llano
OSCAR GONZALEZ de LLANO
Special Assistant United States Attorney
Attorneys for Defendant
Case 1:25-cv-00999-KES-FJS Document 13 Filed 11/05/25 Page 2 of 3

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ORDER
Pursuant to the parties’ stipulation, and good cause appearing, Defendant shall have a 30-day
extension of time to December 19, 2025, to respond to Plaintiff’s complaint. All other deadlines in the
Court’s Scheduling Order are modified accordingly.
IT IS SO ORDERED.
Dated: November 5, 2025 /s/ Barbara A. McAuliffe _
UNITED STATES MAGISTRATE JUDGE
Case 1:25-cv-00999-KES-FJS Document 13 Filed 11/05/25 Page 3 of 3