(SS) Rodriguez v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER FOR EXTENSION OF TIME, signed by Magistrate Judge Gary S. Austin on 9/11/2020. (Apodaca, P)

1
2
3
4
5
6

JONATHAN O. PENA, ESQ.
CA Bar ID No. 278044
Peña & Bromberg, PLC
2440 Tulare St., Suite 320
Fresno, CA 93721
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff
UNITED STATES DISTRICT COURT

7

EASTERN DISTRICT OF CALIFORNIA

8
9

)
)
)
)
)
)
)
)
)
)
)
)

ARTHUR ANTHONY RODRIGUEZ,

10

Plaintiff,

11

vs.

12
13

ANDREW SAUL,
Commissioner of Social Security,

14

Defendant.

15

Case No. 1:20-cv-00055-GSA
STIPULATION AND ORDER
FOR EXTENSION OF TIME

16
17

IT IS HEREBY STIPULATED, by and between the parties through their respective

18

counsel of record, with the Court’s approval, that Plaintiff shall have a 30-day extension of time,

19

from September 16, 2020 to October 16, 2020, for Plaintiff to serve on defendant with

20

PLAINTIFF’S OPENING BRIEF. All other dates in the Court’s Scheduling Order shall be

21

extended accordingly.
This is Plaintiff’s first request for an extension of time. Plaintiff respectfully states that

22
23

the requested extension is necessary due several merit briefs being due on the same week.

24

Counsel requires additional time to brief the issues thoroughly for the Court’s consideration.

25

Defendant does not oppose the requested extension. Counsel apologizes to the Defendant and

26

Court for any inconvenience this may cause.

27

///

28

///

1

1
Respectfully submitted,

2
3

Dated: September 10, 2020

PENA & BROMBERG, ATTORNEYS AT LAW

4
By: /s/ Jonathan Omar Pena
JONATHAN OMAR PENA
Attorneys for Plaintiff

5
6
7
8

Dated: September 10, 2020

9
10
11

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

12
By: */s/ Daniel P. Talbert
Daniel P. Talbert
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on September 10, 2020)

13
14
15
16
17
18

IT IS SO ORDERED.
Dated:

September 11, 2020

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

19
20
21
22
23
24
25
26
27
28

2