(SS) Ramirez v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Erica P. Grosjean on September 16, 2022, as follows: Pursuant to the parties' stipulation (ECF No. 19 ), IT IS SO ORDERED that Defendant shall have an extension, up to and including October 21, 2022, to file her response to Plaintiff's Opening Brief. All other deadlines in the Court's scheduling order are extended accordingly.(Rooney, M)

1
2
3
4
5
6
7

PHILLIP A. TALBERT
United States Attorney
PETER THOMPSON
Acting Chief Counsel, Region IX
Social Security Administration
MARLA K. LETELLIER
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

8
9

Attorneys for Defendant
UNITED STATES DISTRICT COURT

10
EASTERN DISTRICT OF CALIFORNIA
11
12

)
)
)
Plaintiff,
)
)
vs.
)
)
KILOLO KIJAKAZI, Acting Commissioner of)
)
Social Security,
)
)
)
Defendant.

Case No.: 1:21-cv-00578-EPG

SANDRA LORRAINE RAMIREZ,
13
14
15
16
17
18

STIPULATION AND ORDER FOR AN
EXTENSION OF TIME
(ECF No. 19)

19
20

Pending the Court’s approval, the time for Defendant to file her Response to Plaintiff’s

21

Opening Brief is extended forty-five (45) days from September 6, 2022, up to and including

22

October 21, 2022. This is the Defendant’s first request for an extension.

23

Defendant regretfully requests this extension due to unexpected illness and other family

24

issues including her father’s fall and subsequent hospitalization. Defendant also apologizes for

25

the late filing of this stipulation. Defendant made an inadvertent calendaring error in this case.

26

Upon discovering the error today, Defendant acted promptly to file this stipulation.

27
28

1

1
2
3

The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

4
5
6
7
8

Respectfully submitted,
Dated: September 15, 2022

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

9
10
11
12

By

13
14

/s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant U.S. Attorney
Attorneys for Defendant

15
16
17
18
19

Dated: September 15, 2022

PENA & BROMBERG
By

/s/ Jonathan Pena*
(*as authorized via e-mail on June 29, 2022)
JONATHAN PENA
Attorney for Plaintiff

20
21
22
23
24
25
26
27
28

2

1
2

ORDER
Pursuant to the parties’ stipulation (ECF No. 19), IT IS SO ORDERED that Defendant

3

shall have an extension, up to and including October 21, 2022, to file her response to Plaintiff’s

4

Opening Brief. All other deadlines in the Court’s scheduling order are extended accordingly.

5
6
7

IT IS SO ORDERED.
Dated:

September 16, 2022

/s/
UNITED STATES MAGISTRATE JUDGE

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3