(SS) Matajcich v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/9/2022 GRANTING Plaintiff a 30-day extension of time to file her Opening Brief. (Mena-Sanchez, L)

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1 2 3 4 5 6 Meghan O. Lambert CA Bar ID No.: 258040 Osterhout Berger Disability Law 521 Cedar Way, Suite 200 Oakmont, PA 15139 Telephone: (412) 794-8003 Facsimile: (412) 794-8039 meghan@mydisabilityattorney.com Attorney for Plaintiff, Santra Fayliene Matajcich 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION 8 9 10 11 12 13 14 15 16 SANTRA FAYLIENE MATAJCICH, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:21-cv-00911-CKD STIPULATION AND ORDER FOR AN EXTENSION OF TIME FOR PLAINTIFF TO FILE HIS OPENING BRIEF 17 18 19 20 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that Plaintiff shall have an extension of time to file her Opening Brief. This is Plaintiff’s first 21 request for extension to file her Opening Brief. There is good cause for this request. The certified 22 administrative record exceeds 2,900 pages and Plaintiff intends on raising multiple fact-intensive 23 issues, which combined with an unusually busy briefing schedule has resulted in the need for this 24 25 26 27 28 request. As the Court is undoubtedly aware, Defendant has been diligently working to “catch-up” the backlog of certified transcripts due in federal court Social Security disability appeals nationwide, which has had the effect of significantly increasing the number of cases calendared 1 2 for briefing; 1 as a result, Plaintiff respectfully requests a 30-day extension of time to file her opening brief to ensure that the issues are fully and concisely presented to the Court. 3 4 5 Plaintiff respectfully requests that this Court grant a 30-day extension to file her Opening Brief, which is currently due on May 16, 2022. The parties further stipulate that the Court’s Scheduling Order shall be modified 6 7 accordingly. Respectfully submitted, 8 9 10 11 May 9, 2022 DATED /s/ Meghan O. Lambert_____________ MEGHAN O. LAMBERT, ESQUIRE Attorney for Plaintiff, Santra Fayliene Matajcich 12 13 14 May 9, 2022 ______ DATED 15 By: /s/Patrick Snyder (*as authorized by email on May 3, 2022) PATRICK SNYDER, ESQUIRE Special Assistant U.S. Attorney Attorneys for Defendant 16 17 18 19 20 ORDER APPROVED AND SO ORDERED. Dated: May 9, 2022 21 22 _____________________________________ CAROLYN K. DELANEY UNITED STATES MAGISTRATE JUDGE 23 24 25 26 27 28 1 In affidavits filed in many Social Security disability appeals from Jebby Rasputnis, SSA’s Executive Director of the Office of Appellate Operations, Defendant reports that the Agency has essentially doubled the rate of production that existed pre-COVID-19 pandemic (from an average of 300-400 hearing transcriptions per week prior to the pandemic and to its current capacity to produce more than 700 per week).

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