(SS) Dennis v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 08/02/22 GRANTING the Defendant until 10/02/22 to Respond to Plaintiff's Complaint.(Licea Chavez, V)
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PHILLIP A. TALBERT
United States Attorney
PETE THOMPSON
Acting Regional Chief Counsel
Oscar Gonzalez de Llano
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: (510) 970-4818
Email: Oscar.Gonzalez@ssa.gov
Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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RALPH DENNIS,
Plaintiff,
v.
KILOLO KIJAKAZI,
Acting Commissioner of Social Security,
Defendant.
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Civil No. 2:22-cv-00759-AC
STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S
COMPLAINT
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The parties stipulate through counsel that Defendant, the Acting Commissioner of Social Security
(the “Commissioner”), shall have an extension of time to respond to Plaintiff’s Complaint in this case.
In support of this request, the Commissioner respectfully states as follows:
1.
Defendant’s response to Plaintiff’s Complaint is due August 3, 2022. Defendant has not
previously requested an extension of this deadline.
2.
The agency’s Office of Appellate Operations (OAO) is responsible for preparation of
CARs. The Commissioner is in contact with OAO to ensure that the certified administrative record
(CAR) is being properly certified for filing. The CAR in this case has not yet been finalized by OAO for
filing. Accordingly, Defendant requests an extension of 60 days to respond to Plaintiff’s Complaint.
3.
Counsel for the Commissioner has consulted with Plaintiff’s counsel who advised that he
has no objections.
4.
This request is made in good faith and is not intended to delay the proceedings in this
matter.
WHEREFORE, Defendant requests an extension of 60 days until October 2, 2022, to respond to
Plaintiff’s Complaint.
Respectfully submitted,
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United Disability Lawyers Group
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Date: August 2, 2022
s/ Betty Herrera *
By:
Betty Herrera
(*as authorized by email)
*Authorized by email on August 2, 2022
Attorneys for Plaintiff
Date: August 2, 2022
PHILIP A. TALBERT
United States Attorney
Eastern District of California
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By:
/s/ Oscar Gonzalez de Llano
OSCAR GONZALEZ de LLANO
Special Assistant United States Attorney
Attorneys for Defendant
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ORDER
APPROVED AND SO ORDERED
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DATED: August 2, 2022
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