(SS) Bernal Madrigal v. Commissioner of Social Security

Filing 12

STIPULATION AND UNOPPOSED MOTION FOR EXTENSION OF TIME; ORDER. Order signed by Magistrate Judge Sheila K. Oberto on 3/5/2025. (Deputy Clerk WAK)

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JONATHAN O. PENA, ESQ.
CA Bar ID No. 278044
Peña & Bromberg, PLC
3467 W. Shaw Ave., Ste 100
Fresno, CA 93711
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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Pending the Court’s approval, IT IS HEREBY STIPULATED, by and between the

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parties through their respective counsel of record, with the Court’s approval, that Plaintiff shall

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have a 60-day extension of time, from March 10, 2025 to May 9, 2025, for Plaintiff to serve on

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defendant with PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT. All other dates in the

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Court’s Scheduling Order shall be extended accordingly.

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LETICIA BERNAL MAGRIGAL,

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Plaintiff,

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vs.

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LELAND DUDEK,
Acting Commissioner of Social Security,1

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Defendant.

Case No. 1:24-cv-01494-SKO
STIPULATION AND UNOPPOSED
MOTION FOR EXTENSION OF TIME;
ORDER
(Doc. 15)

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This is Plaintiff’s first request for an extension of time. Plaintiff respectfully states that

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the requested extension is necessary due several merit briefs being due on the same week. For

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Leland Dudek became the Acting Commissioner of Social Security on February 19, 2025. Pursuant to Rule 25(d)
of the Federal Rules of Civil Procedure, Carolyn Colvin should be substituted for Leland Dudek as the defendant in
this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the
Social Security Act, 42 U.S.C. § 405(g).

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the weeks of March 10, 2025 and March 17, 2025, Plaintiff’s Counsel has fifteen Merit Briefs

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due. Counsel requires additional time to brief the issues thoroughly for the Court’s consideration.

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Defendant does not oppose the requested extension. Counsel apologizes to the Defendant and

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Court for any inconvenience this may cause.

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Respectfully submitted,

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Dated: March 4, 2025

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: March 4, 2025

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PHILLIP A. TALBERT
United States Attorney
MATHEW W. PILE
Associate General Counsel
Office of Program Litigation
Social Security Administration

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By: */s/ Justin Lane Martin
Justin Lane Martin
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on March 4, 2025)

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ORDER

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Pursuant to the parties’ stipulation and unopposed motion, (Doc. 15), and for good cause

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shown, IT IS SO ORDERED that Defendant shall have an extension of 60 days, to May 9, 2025,
to file the Commissioner’s responsive brief. All other dates in the Scheduling Order (Doc. 5) are
enlarged accordingly.
IT IS SO ORDERED.
Dated:

/s/ Sheila K. Oberto

March 5, 2025

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.

UNITED STATES MAGISTRATE JUDGE

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