(SS) Medina v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Gary S. Austin on July 29, 2022, granting defendant an extension of time to 9/30/2022 to respond to plaintiff's complaint. (Rooney, M)

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1 2 3 4 5 6 7 PHILLIP A. TALBERT United States Attorney PETE THOMPSON Acting Regional Chief Counsel MARGARET LEHRKIND Special Assistant United States Attorney Social Security Administration 160 Spear Street, Suite 800 San Francisco, CA 94105 Telephone: (510) 970-4829 Email: Margaret.Lehrkind@ssa.gov Attorneys for Defendant 8 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 13 14 DANIELLA VIVIANA MIRANDA MEDINA, Plaintiff, v. 15 16 17 KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant. 18 ) ) ) ) ) ) ) ) ) ) ) ) Civil No. 1:22-cv-00519-GSA STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT 19 20 21 The parties stipulate through counsel that Defendant, the Acting Commissioner of Social Security 22 (the “Commissioner”), shall have an extension of time to respond to Plaintiff’s Complaint in this case. 23 In support of this request, the Commissioner respectfully states as follows: 24 25 1. Defendant’s response to Plaintiff’s Complaint is due August 1, 2022. Defendant has not previously requested an extension of this deadline. 26 2. Defendant’s counsel was added as an attorney to this case on July 29, 2022. 27 3. The certified administrative record (CAR) in this case has not been finalized for filing. 28 The agency’s Office of Appellate Operations (OAO) is responsible for preparation of CARs. Counsel 1 for the Commissioner is in contact with OAO to ensure that the CAR is properly certified for filing. 2 Accordingly, Defendant requests an extension of 60 days to respond to Plaintiff’s Complaint. 3 4. Counsel for the Commissioner has consulted with Plaintiff’s counsel who advised that he 4 has no objections. 5 5. 6 7 This request is made in good faith and is not intended to delay the proceedings in this matter. WHEREFORE, Defendant requests until September 30, 2022, respond to Plaintiff’s Complaint. 8 Respectfully submitted, 9 10 Date: July 29, 2022 11 By: /s/ Francesco Paulo Benavides * Francesco Paulo Benavides *Authorized by email on July 29, 2022 Attorneys for Plaintiff 12 13 14 Law Offices of Francesco Benavides Date: July 29, 2022 15 PHILIP A. TALBERT United States Attorney Eastern District of California 16 By: /s/ Margaret Lehrkind MARGARET LEHRKIND Special Assistant United States Attorney Attorneys for Defendant 17 18 19 20 21 22 ORDER 23 24 IT IS SO ORDERED. 25 26 27 28 Dated: July 29, 2022 /s/ Gary S. Austin UNITED STATES MAGISTRATE JUDGE

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