Holland-Johnson v. Commissioner of Social Security

Filing 14

STIPULATED Motion and ORDER for Extension of Time signed by Magistrate Judge Gary S. Austin on 1/4/2015. (Martinez, A)

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KELSEY BROWN, CA #263109
Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383

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Phone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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FRESNO DIVISION
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MELODY HOLLAND-JOHNSON,
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Plaintiff,

Case # 1:14-CV-00913-GSA

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vs.

STIPULATED MOTION AND ORDER FOR
EXTENSION OF TIME

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COMMISSIONER OF SOCIAL SECURITY
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Defendant.
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The parties hereby stipulate by counsel, with the Court’s approval as indicated by

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issuance of the attached Order, that Plaintiff shall have a first 30-day extension of time to file
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Plaintiff’s confidential memo.

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Counsel for the Plaintiff has a heavy caseload and does not have additional attorneys to
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help with this caseload at this time. As a result, counsel for Plaintiff requires additional time to
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draft the confidential memo. The memo is currently due on December 31, 2014. Plaintiff
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requests an 30 day extension of time to January 31, 2015.
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Page 1

MOTION
[1:14-CV-00913-GSA]

Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]

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The parties stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Dated December 30, 2014:

/s/ Kelsey M Brown
KELSEY MACKENZIE BROWN CA #263109
Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]
Attorney for Plaintiff

Dated December 31, 2014:

s/ KELSEY M. BROWN for Kevin Gill
KEVIN GILL
(per e-mail authorization of Assistant Regional Counsel
April Alongi)
Special Assistant U.S. Attorney
Office of the General Counsel
Attorney for Defendant

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ORDER

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Based on the parties’ stipulation set forth above, the Court grants Plaintiff an extension of

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time of thirty (30) days to serve her confidential letter brief. Accordingly, Plaintiff shall serve
her confidential letter brief on or before January 30, 2015.1 The Court’s Scheduling Order (Doc.
6) is modified accordingly.

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IT IS SO ORDERED.
Dated:

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January 4, 2015

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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The parties requested that the deadline for Plaintiff to serve her letter brief be extended to January 31, 2015;
however, the deadline for Plaintiff to serve her letter brief shall be January 30, 2015 because January 31 st is a
Saturday, and a 30-day extension re-sets the deadline to January 30, 2015 in any event,

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MOTION
[1:14-CV-00913-GSA]

Dellert Baird Law Offices, PLLC
PO Box 3757
Silverdale, WA 98383
[phone]