(SS) Garcia Esparza v. Commissioner of Social Security

Filing 15

Stipulation and Order for extension of time, signed by Magistrate Judge Sheila K. Oberto on 1/7/2022. (Rosales, O.)

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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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Oralia Garcia Esparza,
vs.
Kilolo Kijakazi, Acting
Commissioner of Social Security,

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Defendant.

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Case No. 1:21-cv-00991-SKO
STIPULATION AND ORDER FOR
EXTENSION OF TIME
(Doc. 13)

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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 7, 2022 to March 8, 2022, for Plaintiff to

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serve on defendant with PLAINTIFF’S MOTION FOR SUMMARY

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JUDGMENT. All other dates in the Court’s Scheduling Order shall be extended

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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 5, 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 5, 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/ Patrick Snyder
Patrick Snyder
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on January 5, 2022)

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ORDER

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Based upon the foregoing stipulation of the parties (Doc. 13), and for good
cause appearing (Fed. R. Civ. P. 16(b)(4)),

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IT IS HEREBY ORDERED that Plaintiff shall have an extension of time, to

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and including March 8, 2022, in which to file Plaintiff’s motion for summary

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judgment. All other deadlines set forth in the Scheduling Order (Doc. 11) shall be
extended accordingly.

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IT IS SO ORDERED.

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Dated:

/s/ Sheila K. Oberto

January 7, 2022

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UNITED STATES MAGISTRATE JUDGE

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