(SS) Johnson v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER signed by Magistrate Judge Erica P. Grosjean on July 29, 2022, as follows: Pursuant to the parties' stipulation (ECF No. 23 ), IT IS HEREBY ORDERED that Plaintiff shall file an Opening Brief by October 14, 2022. All remaining deadlines in the Scheduling Order (ECF No 5 ) are extended accordingly.(Rooney, M)

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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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Shane Steven Johnson,
Plaintiff,

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Tonya Arrasmith o/b/o

vs.
Kilolo Kijakazi, Acting
Commissioner of Social Security,

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Defendant.

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Case No. 1:21-cv-01066-AWI-EPG
STIPULATION AND ORDER FOR
EXTENSION OF TIME

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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 60-day extension of time,

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from August 15, 2022 to October 14, 2022, for Plaintiff to serve on defendant with Plaintiff’s

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Opening Brief. All other dates in the Court’s Scheduling Order shall be extended accordingly.

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This is Plaintiff’s second request for an extension of time.

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In the months of May through July 21, 2022, Counsel has received an influx of Social

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Security Certified Administrative Records (CAR) from the Eastern District. A review of the

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records received shows Counsel has received at least 50 CARs, the majority of which were filed

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in June 2022.

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Additionally, for the weeks of August 1, 2022 and August 8, 2022, Counsel currently has

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18 merit briefs, and several letter briefs and reply briefs. Additional time is needed to thoroughly

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brief this matter for the Court.

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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: July 22, 2022 PENA & BROMBERG, ATTORNEYS AT LAW

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

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Dated: July 25, 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 July 25, 2022)

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ORDER
Pursuant to the parties’ stipulation (ECF No. 23), IT IS HEREBY ORDERED that

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Plaintiff shall file an Opening Brief by October 14, 2022. All remaining deadlines in the

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Scheduling Order (ECF No. 5) are extended accordingly.

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IT IS SO ORDERED.
Dated:

July 29, 2022

/s/
UNITED STATES MAGISTRATE JUDGE

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