(SS) Ramirez v. Commissioner of Social Security

Filing 21

Stipulation and Order for extension of time, signed by Magistrate Judge Erica P. Grosjean on 9/9/2021. (Filing Deadline: 10/15/2021)(Rosales, O.)

Case 1:20-cv-00985-EPG Document 21 Filed 09/09/21 Page 1 of 3

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DOLLY M. TROMPETER
CA Bar ID No. 235784
Peña & Bromberg, PLC
2440 Tulare St., Suite 320
Fresno, CA 93721
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Plaintiff,

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Kenneth Edward Ramirez,

vs.
Kilolo Kijakazi, Acting
Commissioner of Social Security,

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Defendant.

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Case No. 1:20-cv-00985-EPG
STIPULATION AND ORDER FOR
EXTENSION OF TIME
(ECF No. 20)

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

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

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from September 15, 2021 to October 15, 2021, for Plaintiff to serve on defendant with

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

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extended accordingly.

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This is Plaintiff’s second request for an extension of time but first for this task. Plaintiff

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respectfully states that the requested extension is necessary due several merit briefs being due on

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the same week. Counsel has due two Reply Briefs, two Motions for Summary Judgment, four

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Case 1:20-cv-00985-EPG Document 21 Filed 09/09/21 Page 2 of 3

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Opening Briefs, one Plaintiff’s Memorandum, and one Plaintiff’s Portion of Joint Submission

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due the same week.

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Counsel has recently received a greater number of Answers and Certified Administrative

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Records from defendant in cases in this district, and the three other California Districts, each of

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which require settlement negotiations or merit briefing. Counsel has a greater than usual number

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of merit briefs due in September 2021. Thus, Counsel is requesting an extension into October

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2021 to accommodate the number of cases due in September 2021. Also, Counsel is in the process

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of increasing support staff to accommodate the increase in the number of cases at the briefing

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stage.

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Defendant does not oppose the requested extension. Counsel apologizes to the Defendant
and Court for any inconvenience this may cause.

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Respectfully submitted,

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Dated: September 8, 2021

PENA & BROMBERG, ATTORNEYS AT LAW

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By: /s/ Dolly M. Trompeter
DOLLY M. TROMPETER
Attorneys for Plaintiff

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Dated: September 8, 2021

PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By: */s/ Marcelo N. Illarmo
Marcelo N. Illarmo
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on September 8, 2021)

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Case 1:20-cv-00985-EPG Document 21 Filed 09/09/21 Page 3 of 3

ORDER

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Based on the above stipulation, IT IS ORDERED that Plaintiff shall serve

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Defendant with Plaintiff’s Opening Brief no later than October 15, 2021. All other

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deadlines in the Court’s scheduling order are extended accordingly.

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IT IS SO ORDERED.

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Dated:

September 9, 2021

/s/
UNITED STATES MAGISTRATE JUDGE

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