(SS) Burr v. Commissioner of Social Security

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JONATHAN O. PENA
CA Bar ID No. 278044
Peña & Bromberg, PLC
3467 W. Shaw Ave., Ste 100
Fresno, CA 93711
Telephone: 559-439-9700
Fax: 866-282-6709
info@jonathanpena.com
Attorney for Plaintiff
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Judy Lynn Burr,
Plaintiff,
vs.
COMMISSIONER OF SOCIAL
SECURITY,
Defendant.
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Case No. 1:25-cv-01334-JLT-GSA
MOTION FOR EXTENSION OF
TIME
Plaintiff respectfully moves for an extension of time to file the
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT. Plaintiff’s current
deadline is January 5, 2026. Plaintiff requests an additional 60 days, up to and
including March 6, 2026, to file the brief. All other dates in the Court’s Scheduling
Order shall be extended accordingly.
This request is made in good faith and not for the purpose of delay. For the
weeks of December 29, 2025 and January 5, 2026, Plaintiff’s Counsel has nineteen
merit briefs due and three reply briefs due. Counsel requires additional time due to
multiple overlapping briefing deadlines in other Social Security matters pending

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before the Court and before the administrative agency. The additional time will
allow counsel to fully develop and present the issues for the Court’s consideration.
Plaintiff’s counsel attempted to contact Defendant’s counsel on December 29,
2025 and made a follow up on January 5, 2026, to obtain a stipulation for this
extension but did not receive a response in time to file a joint request. Due to the
preplanned vacations of Plaintiff’s counsel and the intervening holidays, Plaintiff
was unable to file the motion on that same day counsel attempted to contact
Defendant’s counsel to obtain a stipulation for this extension but did not receive a
response in time to file a joint request.
This is Plaintiff’s first request for an extension in this matter. Plaintiff
apologizes to the Court for any inconvenience and respectfully requests that the
Court grant the requested extension.
Respectfully submitted,
Dated: January 5, 2026 PENA & BROMBERG, ATTORNEYS AT LAW
By: /s/ JONATHAN O. PENA
JONATHAN O. PENA
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Judy Lynn Burr,
Plaintiff,
vs.
COMMISSIONER OF SOCIAL
SECURITY,
Defendant.
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Case No. 1:25-cv-01334-JLT-GSA
ORDER FOR EXTENSION OF
TIME
Based upon the Plaintiff’s Motion for an extension of time, for good cause
shown, it is ORDERED that that Plaintiff shall have an extension of time, from
January 5, 2026 to March 6, 2026, 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.
IT IS SO ORDERED.
IT IS SO ORDERED.
Dated: January 5, 2026 /s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE