# PRE-HEARING BRIEF **Claimant:** Maria Ramirez **SSN:** XXX-XX-1234 **Hearing office:** OHO Sacramento **ALJ:** Hon. [TBD] **Hearing date:** 2026-06-12 ## I. Procedural posture Claimant filed for Title II SSDI benefits on 2025-08-04, alleging onset of 2025-02-15 due to chronic lumbar radiculopathy and major depressive disorder. The initial application was denied on 2025-11-20; reconsideration was denied on 2026-02-08. Claimant filed Form HA-501 within the 60-day window on 2026-03-22. ## II. Sequential evaluation (20 C.F.R. § 404.1520) 1. **SGA**: Claimant has not engaged in substantial gainful activity since the alleged onset date. Earnings record (Exhibit 8E) shows no quarters above the SGA threshold. 2. **Severe impairment**: Lumbar radiculopathy supported by MRI (Exhibit 4F) and treating-physician opinion (Exhibit 7F). Major depression supported by treatment records (Exhibits 5F, 6F). 3. **Listings**: Claimant respectfully argues the combination of impairments equals Listing 1.15 (disorders of the spine). *See* SSR 17-2p. 4. **RFC**: Treating provider Dr. Patel limits Claimant to sedentary work with additional postural and concentration restrictions. The reconsideration RFC understated Claimant's limitations. 5. **Past relevant work**: Claimant's prior work as a warehouse picker exceeded sedentary capacity. 6. **Other work / grids**: Under Medical-Vocational Rule 201.14, a finding of disabled is appropriate. ## III. Requested findings Award benefits with onset of 2025-02-15. Respectfully submitted, [Founder name TODO], Esq. California Bar No. [TBD]
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