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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

 

MANUEL A., ) 

 ) 

 Plaintiff, ) 

 ) No. 1:20-cv-03844 

 v. ) 

 ) Magistrate Judge Jeffrey I. Cummings 

KILOLO KIJAKAZI, Acting ) 

Commissioner of Social Security,1 ) 

 ) 

 Defendant. ) 

 

MEMORANDUM OPINION AND ORDER 

 Manuel A. (“Claimant”) brings a motion to reverse the final decision of the 

Commissioner of Social Security (“Commissioner”) denying his application for Disability 

Insurance Benefits (“DIBs”). The Commissioner brings a motion for summary judgment 

seeking to uphold the decision to deny benefits. The parties have consented to the jurisdiction of 

a United States Magistrate Judge pursuant to 28 U.S.C. §636(c). This Court has jurisdiction to 

hear this matter pursuant to 42 U.S.C. §405(g). For the reasons discussed herein, Claimant’s 

motion to reverse the decision of the Commissioner, (Dckt. #17), is granted and the 

Commissioner’s motion for summary judgment, (Dckt. #20), is denied. 

I. BACKGROUND 

 Claimant first filed a disability application on May 17, 2013, alleging a disability onset 

date of March 1, 2009. His claim was denied initially and upon reconsideration. On December 

9, 2015, Administrative Law Judge (“ALJ”) Kimberly S. Cromer issued an unfavorable decision 

denying Claimant’s application for benefits. Claimant appealed to the District Court, which 

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 In accordance with Internal Operating Procedure 22 - Privacy in Social Security Opinions, the Court 

refers to plaintiff only by his first name and the first initial of his last name. Acting Commissioner of 

Social Security Kilolo Kijakazi has also been substituted as the named defendant. Fed.R.Civ.P. 25(d). 

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reversed the ALJ’s decision and remanded the case for further consideration. (R. 605-19). On 

remand, Claimant amended his alleged onset date to November 6, 2012, and indicated that his 

date last insured was December 31, 2015. (R. 1878-79). ALJ Cromer held a supplemental 

hearing on March 18, 2019, (R. 515-64), and again denied benefits on May 20, 2019, (R. 1875-

1911). The Appeals Council declined to assume jurisdiction, (R. 1868-74), leaving the ALJ’s 

decision as the final decision of the Commissioner. See 20 C.F.R. §404.984. This action 

followed. 

B. The Social Security Administration Standard

To qualify for disability benefits, a claimant must demonstrate that he is disabled, 

meaning he cannot “engage in any substantial gainful activity by reason of any medically 

determinable physical or mental impairment which can be expected to result in death, or which 

has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 

U.S.C. §423(d)(1)(A). Gainful activity is defined as “the kind of work usually done for pay or 

profit, whether or not a profit is realized.” 20 C.F.R. §404.1572(b). 

The Social Security Administration (“SSA”) applies a five-step analysis to disability 

claims. 20 C.F.R. §404.1520. The SSA first considers whether the claimant has engaged in 

substantial gainful activity during the claimed period of disability. 20 C.F.R. §404.1520(a)(4)(i). 

At step two, the SSA determines whether a claimant has one or more medically determinable 

physical or mental impairments. 20 C.F.R. §404.1521. An impairment “must result from 

anatomical, physiological, or psychological abnormalities that can be shown by medically 

acceptable clinical and laboratory diagnostic techniques.” Id. In other words, a physical 

or mental impairment “must be established by objective medical evidence from an acceptable 

medical source.” Id.; Shirley R. v. Saul, 1:18-cv-00429-JVB, 2019 WL 5418118, at *2 (N.D.Ind. 

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Oct. 22, 2019). If a claimant establishes that he has one or more physical or mental impairments, 

the ALJ then determines whether the impairment(s) standing alone, or in combination, are severe 

and meet the twelve-month duration requirement noted above. 20 C.F.R. §404.1520(a)(4)(ii). 

At step three, the SSA compares the impairment or combination of impairments found at 

step two to a list of impairments identified in the regulations (“the listings”). The specific 

criteria that must be met to satisfy a listing are described in Appendix 1 of the regulations. 20 

C.F.R. Pt. 404, Subpt. P, App. 1. If the claimant’s impairments meet or “medically equal” a 

listing, she is considered disabled and no further analysis is required. If the listing is not met, the 

analysis proceeds. 20 C.F.R. §404.1520(a)(4)(iii). 

Before turning to the fourth step, the SSA must assess the claimant’s residual functional 

capacity (“RFC”), or his capacity to work in light of the identified impairments. Then, at step 

four, the SSA determines whether the claimant is able to engage in any of his past relevant 

work. 20 C.F.R. §404.1520(a)(4)(iv). If the claimant can do so, he is not disabled. Id. If the 

claimant cannot undertake his past work, the SSA proceeds to step five to determine whether a 

substantial number of jobs exist that the claimant can perform given his RFC, age, education, and 

work experience. If such jobs exist, he is not disabled. 20 C.F.R. §404.1520(a)(4)(v). 

 C. The Evidence Presented to the ALJ 

 Because Claimant’s arguments concern only his mental limitations, the Court will limit 

its discussion of the evidence accordingly. 

 1. Evidence from Treating Physicians 

 From May through September 2014, Claimant’s primary care physician, Dilip Patel, 

M.D., prescribed trazodone to treat Claimant’s depression and insomnia. (R. 402-03). When 

Claimant began seeing a new doctor, Deepti Shivakumar, M.D., in October, he continued to 

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report feelings of depression and frequent crying spells. (R. 407). Dr. Shivakumar started 

Claimant on Lexapro, increased his dosage of Gabapentin, and referred him to a psychiatrist. (R. 

406-07). 

 Psychiatrist Evan Deranja, M.D., began treating Claimant on March 17, 2015. At that 

time, Claimant reported experiencing depressed mood, insomnia, anhedonia, feelings of guilt and 

worthlessness, poor energy, poor concentration, and decreased appetite. (R. 443). Claimant 

reported that his concentration had worsened over time – a change which he suspected led to him 

losing his job. (Id.). Dr. Deranja noted that Claimant was taking Lexapro and Ambien daily, 

with no benefit. (R. 445). He observed psychomotor retardation, depressed mood with a 

constricted affect, and cognitive difficulties. (R. 445-46). He concluded that Claimant was 

experiencing a “major depressive episode – single episode – [that had] been worsening for the 

past [one to two] years” and a “cognitive disorder not otherwise specified.” (R. 446). 

 Regarding the cognitive disorder, Dr. Deranja explained that Claimant’s “symptoms of 

depression [were] complicated by some significant potential contributing factors,” possibly 

related to Claimant’s history of exposure to paint fumes from his three-decade career as a 

painter. (R. 443). In particular, Dr. Deranja suspected that Claimant suffered from a syndrome 

known as chronic solvent-induced encephalopathy (“CSE”), which he theorized played a larger 

role in Claimant’s mental limitations than depression or anxiety. (R. 446). He increased 

Claimant’s dosages of Lexapro and trazodone and referred him for cognitive testing. (R. 443). 

 Dr. Deranja administered the Montreal Cognitive Assessment (“MoCA Test”) – a 

cognitive screening exam for early detection of mild cognitive impairment – to Claimant on 

September 28, 2015. Claimant scored a thirteen out of thirty, indicating significant defects. (R. 

455). Dr. Deranja noted that it would “still be helpful for [Claimant] to have formal 

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neurocognitive testing,” as he was “not sure if MoCA [was] enough” to verify the existence of 

CSE. (R. 456). He again hypothesized that some of Claimant’s “difficulties with memory, 

thinking, etc. . . . may be caused from [his] inhalation of paint solvents for [thirty plus] years,” 

and referred Claimant for a neuropsychological examination. (Id.). Despite Dr. Deranja’s 

recommendation, Claimant never received this testing because his insurance would not cover it. 

(R. 58, 522-23). 

 Dr. Deranja completed a Mental Impairment Report on Claimant’s behalf on October 6, 

2015. In it, he noted that Claimant suffered from depressive disorder and “cognitive disorder not 

otherwise specified.” (R. 429). He endorsed symptoms of depressed mood, anhedonia, 

insomnia, impaired concentration, daily headaches, a tendency to be easily overwhelmed, 

decreased appetite, decreased energy, feelings of guilt and worthlessness, and psychomotor 

retardation. According to Dr. Deranja, Claimant’s depression caused moderate limitations in 

activities of daily living and maintaining social functioning, as well as marked limitations in 

maintaining concentration, persistence, or pace. (Id.). Comparatively, he found that Claimant’s 

unidentified cognitive disorder caused marked limitations in all four functional categories. (R. 

432) (“While depression is a confounder, this author suspects that his cognitive deficits extend 

beyond that seen with depression.”). 

 Dr. Deranja was still seeing Claimant on March 5, 2019, when he wrote a letter 

summarizing Claimant’s treatment history. He again indicated that Claimant’s symptoms of 

depression were “complicated by significant potential contributing factors, most notably his 

exposure to various chemicals when he was a painter for [thirty] years.” (R. 1865). He also 

reiterated that: (1) “formal neurocognitive testing would be very helpful in assessing more details 

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of his current cognitive strengths and limitations,” (2) the 2015 MoCA testing evidenced a 

serious cognitive disorder, and (3) Claimant struggled with activities of daily living. (Id.). 

 2. Evidence from Medical Expert Testimony 

 Psychological medical expert Jeffrey Andert, Ph.D., testified at Claimant’s March 18, 

2019 supplemental hearing. He confirmed that the record supports a diagnosis of major 

depressive disorder, which he characterized as recurrent and moderate. (R. 522). 

 Dr. Andert acknowledged that Claimant’s 2015 MoCA score suggested “extremely poor 

functioning,” and that an individual performing at this level would have a great deal of difficulty 

even with day-to-day functioning. (Id.). He further explained that “it would be unlikely” for 

Claimant’s score to be attributable solely to depressive symptoms, as depression “would not 

account . . . for cognitive deficits at that estimated level.” (R. 533). He acknowledged Dr. 

Deranja’s theory that Claimant had a cognitive impairment, but opined that there was insufficient 

evidence to confirm this theory. (R. 523). Dr. Andert agreed that a neuropsychological 

investigation would have been appropriate to confirm the existence of a cognitive impairment. 

(R. 522). 

 Dr. Andert concluded that Claimant had only moderate limitations in each functional 

category. (R. 524-25). He recommended that Claimant be limited to simple, routine, and 

repetitive tasks, with no fast-paced work on a routine basis. (R. 525). He added that Claimant 

could work toward a daily quota of productivity and could tolerate and engage in a full range of 

interaction with coworkers, supervisors, and the public. (R. 526). Dr. Andert based these 

findings “on the record as it stands, absent any support for the suspicion of any cognitive 

deficits.” (R. 524). 

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 D. The ALJ’s Decision 

The ALJ applied the five-step inquiry required by the Act in reaching her decision to 

deny Claimant’s request for benefits. At step one, the ALJ found that Claimant did not engage in 

substantial gainful activity from his alleged onset date of November 6, 2012, through his date 

last insured. (R. 1880). At step two, she determined that Claimant suffered from the severe 

impairments of diabetes mellitus, peripheral neuropathy, degenerative disc disease, insomnia, 

depression, and anxiety. (Id.). At step three, the ALJ concluded that Claimant did not have an 

impairment or combination of impairments that met or medically equaled one of the 

Commissioner’s listed impairments, including listing 12.04 (depressive, bipolar, and related 

disorders) and 12.06 (anxiety and obsessive-compulsive disorders). (R. 1884). 

 Before turning to step four, the ALJ determined that Claimant had the RFC to perform 

sedentary work with several physical limitations and the following non-physical limitations: 

He was limited to simple, routine, repetitive work with no interaction with the 

public as part of routine job duties. He could have only occasional interaction with 

coworkers and supervisors. He could have no fast-paced production assembly line 

work or work where a machine is setting the pace, but allowing for work at a 

variable rate. He could do no tandem work. 

(R. 1888). At step four, the ALJ determined that Claimant could not have performed his past 

relevant work as a paint line supervisor or production supervisor through his date last insured. 

(R. 1901). Even so, at step five, the ALJ concluded that a sufficient number of jobs existed in 

the national economy that Claimant could have performed given his RFC, age, education, and 

experience, including the representative jobs of sorter, document preparer, and circuit board 

assembler. (R. 1902). As such, the ALJ found that Claimant was not under a disability at any 

time from November 6, 2012, through December 31, 2015. (R. 1903). 

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II. STANDARD OF REVIEW 

 A claimant who is found to be “not disabled” may challenge the Commissioner’s final 

decision in federal court. Judicial review of an ALJ’s decision is governed by 42 U.S.C. 

§405(g), which provides that “[t]he findings of the Commissioner of Social Security as to any 

fact, if supported by substantial evidence, shall be conclusive.” 42 U.S.C. §405(g). “Substantial 

evidence is not a high threshold: it means only ‘such relevant evidence as a reasonable mind 

might accept as adequate to support a conclusion.’” Karr v. Saul, 989 F.3d 508, 511 (7th Cir. 

2021), quoting Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019) (internal quotation marks 

omitted). The Commissioner’s decision must also be based on the proper legal criteria and free 

from legal error. Scheck v. Barnhart, 357 F.3d 697, 699 (7th Cir. 2004); Steele v. Barnhart, 290 

F.3d 936, 940 (7th Cir. 2002). 

 A court reviews the entire record, but it does not displace the ALJ’s judgment by 

reweighing the facts, resolving conflicts, deciding credibility questions, making independent 

symptom evaluations, or otherwise substituting its judgment for that of the Commissioner. 

McKinzey v. Astrue, 641 F.3d 884, 889 (7th Cir. 2011); Elder v. Astrue, 529 F.3d 408, 413 (7th 

Cir. 2008). Instead, the court looks at whether the ALJ articulated an “accurate and logical 

bridge” from the evidence to her conclusions. Craft v. Astrue, 539 F.3d 668, 673 (7th Cir. 2008). 

This requirement is designed to allow a reviewing court to “assess the validity of the agency’s 

ultimate findings and afford a claimant meaningful judicial review.” Scott v. Barnhart, 297 F.3d 

589, 595 (7th Cir. 2002). Thus, even if reasonable minds could differ as to whether the claimant 

is disabled, courts will affirm a decision if the ALJ’s opinion is adequately explained and 

supported by substantial evidence. Elder, 529 F.3d at 413 (citation omitted). 

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III. ANALYSIS 

 Because the ALJ failed to develop a full and fair record, as was her duty, this case must 

be remanded for further consideration. “While a claimant bears the burden of proving disability, 

the ALJ in a Social Security hearing has a duty to develop a full and fair record.” Nelms v. 

Astrue, 553 F.3d 1093, 1098 (7th Cir. 2009), (citing Smith v. Apfel, 231 F.3d 433, 437 (7th Cir. 

2000); Thompson v. Sullivan, 933 F.2d 581, 585 (7th Cir.1991)). Although this duty is 

“heightened” when a claimant appears pro se, Skinner v. Astrue, 478 F.3d 836, 841 (2007), it 

applies “[e]ven when a claimant is represented by counsel,” Moran v. Astrue, 569 F.3d 108, 112 

(2d Cir. 2009). Failure to fulfill this obligation is “good cause” to remand for the gathering of 

additional evidence. Thompson, 933 F.2d at 586. 

In this case, Claimant argues that the ALJ failed to adequately develop the record when 

she chose not to order neuropsychological testing to verify whether Claimant suffered from a 

cognitive disorder. (Dckt. #17 at 11). Because the Court agrees that this omission prejudiced 

Claimant, a remand to the SSA is warranted. Although the Court need not (and does not) 

address Claimant’s remaining arguments, see, DeCamp v. Berryhill, 916 F.3d 671, 676 (7th Cir. 

2019), this decision should not be construed as a comment on the merits of those arguments, 

which Claimant is free to assert on remand. 

A. Without additional neuropsychological testing, the ALJ lacked sufficient 

evidence to determine whether Claimant was disabled. 

 “It is axiomatic that the claimant bears the burden of supplying adequate records and 

evidence to prove their claim of disability.” Scheck, 357 F.3d at 702 (citing 20 C.F.R. 

§404.1512(c)). Even so, an ALJ’s duty to seek additional evidence is triggered when “the 

evidence before her is insufficient to determine whether a claimant is disabled or, if after 

weighing the conflicting evidence, she cannot reach a conclusion.” Luna v. Shalala, 22 F.3d 

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687, 693 (7th Cir. 1994). Courts “generally uphold[] the reasoned judgment of the ALJ on how 

much evidence to gather.” Nelms, 553 F.3d at 1098. Accordingly, “a significant omission” is 

usually required before courts will find that an ALJ failed to fulfill this duty. Id. (citing Luna, 22 

F.3d at 692). An omission is “significant” only if it is prejudicial. Nelson v. Apfel, 131 F.3d 

1228, 1235 (7th Cir. 1997). In this case, the Court finds that it was. 

The ALJ did not consider any limitations stemming from Claimant’s cognitive 

impairment. Instead, she cited Dr. Andert’s testimony that the evidence in the record was 

“insufficient to support a cognitive impairment” at least eight times throughout her decision. 

Most notably, she relied on this testimony when assessing only moderate limitations in the 

paragraph B categories, (R. 1882-1883, 1885, 1897), when explaining her decision to give little 

weight to Dr. Deranja’s 2015 report finding that Claimant had marked limitations in all four 

functional categories, (R. 1889), and when explaining her decision to give little weight to Dr. 

Deranja’s 2019 letter finding Claimant struggled with activities of daily living, (Id.). 

By repeatedly relying on this portion of Dr. Andert’s testimony in order to avoid 

assessing limitations that may have stemmed from Claimant’s undiagnosed cognitive disorder, 

the ALJ disregarded the District Court’s clear warning that she was not permitted to “rely on the 

absence of [neuropsychological testing] to support a finding that [Claimant] is not disabled if he 

is financially unable to obtain the testing.” (R. 618) (citing Spies v. Colvin, 641 Fed.Appx. 628, 

634-35 (7th Cir. 2016)). See Smith, 231 F.3d at 437-38 (“If the ALJ was concerned that the 

medical evidence was insufficient to determine whether Mr. Smith was disabled, he should have 

ordered more recent X-rays.”); Delph v. Berryhill, No. 1:16-cv-02461-TWP-DML, 2018 WL 

816856, at *5 (S.D.Ind. Jan. 23, 2018) (finding the ALJ erred by failing to order additional 

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testing when “the absence of this testing was one of the ALJ’s explicit reasons for giving the 

opinion of [claimant’s] treating neurologist ‘little to no weight’”). 

This error was particularly prejudicial because Dr. Deranja theorized that most of 

Claimant’s mental limitations stemmed from his cognitive disorder, rather than his depression or 

anxiety. (R. 446). He further hypothesized that Claimant’s CSE caused marked limitations in all 

four paragraph B categories. (R. 432). These theories found support in Claimant’s low score on 

the MoCA test, which Dr. Andert testified would not have been caused by depression alone. (R. 

533). In light of this objective evidence supporting the existence of a cognitive impairment, 

Claimant’s inability to pay for such testing due to insurance constraints, and the evidence 

suggesting that said impairment caused limitations that could theoretically prevent Claimant 

from obtaining work, the ALJ was obligated to develop the record further. 20 C.F.R. 

§404.1529(b) (an ALJ “must develop evidence regarding the possibility of a medically 

determinable mental impairment when the record contains information to suggest that such an 

impairment exists”). 

B. The Court is not convinced that the ALJ would reach the same result if 

additional testing were ordered on remand. 

 The Commissioner next argues that even if additional testing had been necessary at the 

initial hearing, it was too late to order the testing when the ALJ reconsidered the case in 2019. 

Because Claimant’s alleged disability period spanned from November 6, 2012, to December 31, 

2015, the Commissioner asserts that “any results of a neuropsychological evaluation performed 

after the Appeals Council remanded the matter back to the ALJ in July 2018 – no matter what 

they might show – could not establish plaintiff’s condition during the period at issue.” (Dckt. 

#21 at 13). Again, the Court disagrees. 

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 Medical evidence post-dating a claimant’s disability period is “relevant to the extent it 

may reflect the claimant’s impairments on a prior date.” Jones v. Saul, 823 Fed.Appx. 434, 439 

(7th Cir. 2020) (citing Pepper v. Colvin, 712 F.3d 351, 364 (7th Cir. 2013)). Medical experts 

might even provide a “retrospective diagnosis” dating back to the disability period, which could 

support a finding of a past impairment that would have to be accounted for in a claimant’s RFC. 

See, e.g., Allord v. Barnhart, 455 F.3d 818, 822 (7th Cir. 2006) (retrospective diagnosis of PTSD 

supported finding of past impairment); Estok v. Apfel, 152 F.3d 636, 638 (7th Cir. 1998) (“A 

physician’s retrospective diagnosis is a medical opinion of the claimant’s impairments which 

relates back to the covered period.”). “What is required [to establish a retrospective diagnosis] is 

contemporaneous corroboration [contemporaneous with the period of coverage, that is] of the 

mental illness, . . . not necessarily contemporaneous medical corroboration.” Wilder v. Apfel, 

153 F.3d 799, 802 (7th Cir.1998). 

 In other words, the diagnosis can “relate back” so long as it is corroborated by evidence – 

whether medical or lay – derived from the claimant’s period of disability. Allord, 455 F.3d at 

822, quoting Newell v. Commissioner of Social Security, 347 F.3d 541, 547 (3d Cir.2003). 

Furthermore, it is not enough for a diagnosis to relate back: there must also be evidence of 

limitations stemming from that diagnosis that also pre-dated the expiration of the insured period. 

See Estok, 152 F.3d at 640 (“It is not enough to show that [claimant] had received a diagnosis of 

fibromyalgia with a date of onset prior to the expiration of the insured period, since fibromyalgia 

is not always (indeed, not usually) disabling.”).

 In this case, if Dr. Deranja was correct to presume that Claimant contracted CSE during 

his time as a painter, it is possible that a retrospective diagnosis could have been made in 2019. 

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CSE has been shown to cause “irreversible damage to the [central nervous system],” 2 and an 

effective treatment for the condition does not exist.3

 Accordingly, if Claimant acquired the 

condition prior to or during his period of disability, it could have been diagnosed years later. 

Furthermore, because the record contains evidence from during Claimant’s disability period that 

corroborates the existence of a cognitive impairment and the limitations that this impairment 

caused – namely, the MoCA test results and Dr. Deranja’s treatment notes – a post-2015 

diagnosis could “relate back” and support the existence of a cognitive impairment during 

Claimant’s disability period. This is especially likely given the fact that “CSE is a nonprogressive disease with no severe deterioration after cessation of exposure,”4

 meaning that 

Claimant – who has not worked as a painter since his period of disability – could not have 

acquired the impairment since his date last insured, nor could the impairment have worsened in 

the intervening years.5 Accordingly, the Court finds that the ALJ had a duty to supplement the 

record with neuropsychological testing in order to determine the existence of a cognitive 

impairment. 

 Finally, because CSE is irreversible, the same possibility of a retrospective diagnosis 

exists today. In other words, because of the nature of CSE and the facts regarding Claimant’s 

2

 Gert van der Laan, Chronic Solvent-induced Encephalopathy: A step forward, 33 NeuroToxicology 897 

(Aug. 2012). 

3

 Evelien van Valen, et al., Chronic solvent-induced encephalopathy: course and prognostic factors of 

neuropsychological functioning, 91(7) International Archives of Occupational Environmental Health 843 

(Jun. 25, 2018). 

4 See n. 4, supra. 

5

 For these same reasons, the Commissioner’s argument that the ALJ “was not allowed” to order testing 

on remand is also unfounded. The Commissioner cited 20 C.F.R. §404.1519b(c), which provides that the 

SSA will not pay for additional testing when a claimant’s “insured status expired in the past and there is 

no possibility of establishing an onset date prior to the date [his] insured status expired.” As explained 

above, there was a possibility of establishing an earlier onset date through additional testing at the time of 

Claimant’s 2019 hearing.

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exposure to paint fumes, testing today could confirm that Claimant’s cognitive disorder arose 

during his disability period and caused functional limitations. These facts leave the Court 

unconvinced that the ALJ will reach the same result on remand. Karr, 989 F.3d at 511 (an error 

is harmless only if the court is convinced that the ALJ would reach the same result on remand). 

CONCLUSION

 For the foregoing reasons, Claimant’s motion to reverse the Commissioner’s decision to 

deny him DIBs, (Dckt. #17), is granted and the Commissioner’s motion for summary judgment, 

(Dckt. #20), is denied. The decision of the Commissioner is reversed, and the case is remanded 

for further proceedings consistent with this Memorandum Opinion and Order. 

ENTERED: September 29, 2022 

 

 

 ______________________ 

 Jeffrey I. Cummings 

 United States Magistrate Judge 

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