(SS) Matajcich v. Commissioner of Social Security
Filing
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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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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
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION
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SANTRA FAYLIENE MATAJCICH,
Plaintiff,
v.
KILOLO KIJAKAZI,
Acting Commissioner of Social Security,
Defendant.
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Case No.: 2:21-cv-00911-CKD
STIPULATION AND ORDER FOR AN
EXTENSION OF TIME FOR PLAINTIFF TO
FILE HIS OPENING BRIEF
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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
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request for extension to file her Opening Brief. There is good cause for this request. The certified
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administrative record exceeds 2,900 pages and Plaintiff intends on raising multiple fact-intensive
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issues, which combined with an unusually busy briefing schedule has resulted in the need for this
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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
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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.
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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
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accordingly.
Respectfully submitted,
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May 9, 2022
DATED
/s/ Meghan O. Lambert_____________
MEGHAN O. LAMBERT, ESQUIRE
Attorney for Plaintiff, Santra Fayliene Matajcich
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May 9, 2022 ______
DATED
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By:
/s/Patrick Snyder
(*as authorized by email on May 3, 2022)
PATRICK SNYDER, ESQUIRE
Special Assistant U.S. Attorney
Attorneys for Defendant
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ORDER
APPROVED AND SO ORDERED.
Dated: May 9, 2022
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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
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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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