(SS) Parker v. Commissioner of Social Security

Filing 12

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 08/02/22 GRANTING Plaintiff until 09/29/22, for Plaintiff to serve on defendant with Plaintiff's Motion for Summary Judgment. All other dates in the Court's Scheduling Order shall be extended accordingly.(Licea Chavez, V)

1
2
3
4
5
6
7

JONATHAN O. PENA, ESQ.
CA Bar ID No. 278044
Peña & Bromberg, PLC
2440 Tulare St., Suite 320
Fresno, CA 93721
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12

Plaintiff,

13
14
15

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

April Parker,
vs.
Kilolo Kijakazi, Acting
Commissioner of Social Security,

16
17

Defendant.

18
19

Case No. 2:21-cv-01972-AC
STIPULATION AND |PROPOSED|
ORDER FOR EXTENSION OF
TIME

20
21

IT IS HEREBY STIPULATED, by and between the parties through their

22

respective counsel of record, with the Court’s approval, that Plaintiff shall have a

23

45-day extension of time, from August 15, 2022 to September 29, 2022, for

24

Plaintiff to serve on defendant with Plaintiff’s Motion for Summary Judgment. All

25

other dates in the Court’s Scheduling Order shall be extended accordingly.

26

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

27

In the months of May through July 21, 2022, Counsel has received an influx

28

of Social Security Certified Administrative Records (CAR) from the Eastern
1

1

District. A review of the records received shows Counsel has received at least 50

2

CARs, the majority of which were filed in June 2022.

3

Additionally, for the weeks of August 1, 2022 and August 8, 2022, Counsel

4

currently has 18 merit briefs, and several letter briefs and reply briefs. Additional

5

time is needed to thoroughly brief this matter for the Court.

6
7

Defendant does not oppose the requested extension. Counsel apologizes to
the Defendant and Court for any inconvenience this may cause.

8
9

Respectfully submitted,

10
11

Dated: July 22, 2022

PENA & BROMBERG, ATTORNEYS AT LAW

12
13

By: /s/ Jonathan Omar Pena
JONATHAN OMAR PENA
Attorneys for Plaintiff

14
15
16
17
18
19
20

Dated: July 25, 2022

PHILLIP A. TALBERT
United States Attorney
PETER K. THOMPSON
Acting Regional Chief Counsel, Region IX
Social Security Administration

21
22
23
24
25

By: */s/ Andrea Banks
Andrea Banks
Special Assistant United States Attorney
Attorneys for Defendant
(*As authorized by email on July 25, 2022)

26
27
28

2

|PROPOSED| ORDER

1
2
3

Pursuant to stipulation, IT IS SO ORDERED.

4
5

Dated: August 2, 2022

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3