(SS) Hernandez v. Commisioner of Social Security

Filing 23

ORDER for Extension of Time, signed by Magistrate Judge Barbara A. McAuliffe on 1/11/2022. Opening Brief due 3/11/2022. (Marrujo, C)

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DOLLY M. TROMPETER, ESQ.
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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Gloria Estella Hernandez,
vs.
Kilolo Kijakazi, Acting
Commissioner of Social Security,

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Defendant.

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Case No. 1:20-cv-01112-DAD-BAM
STIPULATION AND ORDER FOR
EXTENSION OF TIME

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

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respective counsel of record, with the Court’s approval, that Plaintiff shall have a

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60-day extension of time, from January 10, 2022 to March 11, 2022, for Plaintiff to

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serve on defendant with PLAINTIFF’S OPENING BRIEF. All other dates in the

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Court’s Scheduling Order shall be extended accordingly.

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This is Plaintiff’s first request for an extension of time. Good cause exists

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for this request. Counsel for the Plaintiff is currently in Houston, Texas due to a

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family emergency involving Counsel’s father who is gravely ill with Leukemia.
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(See Declaration by Dolly M. Trompeter). Counsel for the Plaintiff is a principal

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caregiver. Additionally, Counsel has limited access to her computer and will

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require additional time to brief this matter upon her return to California.

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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: January 10, 2022

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: January 10, 2022

PHILLIP A. TALBERT
United States Attorney
PETER K. THOMPSON
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By: */s/ Sathya Oum
Sathya Oum
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on January 10, 2022)

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ORDER

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Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY
ORDERED, that Plaintiff shall have an extension of time, to and include March 11, 2022, in
which to file Plaintiff’s Opening Brief; and that all other deadlines set forth in the Court’s

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Scheduling Order (Doc. 8) shall be extended accordingly.
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IT IS SO ORDERED.

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Dated:

/s/ Barbara

January 11, 2022

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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