(SS) Dennis v. Commissioner of Social Security

Filing 11

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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1 2 3 4 5 6 7 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 8 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RALPH DENNIS, Plaintiff, v. KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Civil No. 2:22-cv-00759-AC STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 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, 17 United Disability Lawyers Group 18 19 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 20 21 22 23 24 25 26 27 28 By: /s/ Oscar Gonzalez de Llano OSCAR GONZALEZ de LLANO Special Assistant United States Attorney Attorneys for Defendant 1 2 ORDER APPROVED AND SO ORDERED 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: August 2, 2022

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