(SS) See v. Commissioner of Social Security

Filing 11

STIPULATION and ORDER Granting Extension of Time signed by Magistrate Judge Gary S. Austin on 03/05/2025. Filing Deadline: 5/12/2025. (Deputy Clerk EF)

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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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Plaintiff,

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Paeng See,
vs.
Michelle King, ACTING
COMMISIONER
OF SOCIAL
SECURITY1,
Defendant.

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Case No. 1:24-cv-01516-GSA
STIPULATION AND ORDER FOR
EXTENSION OF TIME

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Pending the Court’s approval, IT IS HEREBY STIPULATED, by and

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between the parties through their respective counsel of record, with the Court’s

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approval, that Plaintiff shall have a 60-day extension of time, from March 13, 2025

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to May 12, 2025, for Plaintiff to serve on defendant with PLAINTIFF’S MOTION

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1 Michelle King became the Acting Commissioner of Social Security on January
23, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Michelle
King should be substituted for Carolyn Colvin 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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FOR SUMMARY JUDGMENT. All other dates in the Court’s Scheduling Order

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shall be extended accordingly.

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

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states that the requested extension is necessary due several merit briefs being due

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on the same week. For the weeks of March 10, 2025 and March 17, 2025,

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Plaintiff’s Counsel has fifteen Merit Briefs due. Counsel requires additional time to

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brief the issues thoroughly for the Court’s consideration. Defendant does not

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oppose the requested extension. Counsel apologizes to the Defendant and Court

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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

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 stipulation,

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IT IS SO ORDERED.
Dated:

March 5, 2025

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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