Brown v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 12/29/15 ORDERING that the time for Defendant to respond to Plaintiffs Motion for Summary Judgment be extended 35 days to and including January 28, 2016. (Dillon, M)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARIO LAMONT BROWN,

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Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

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) Case No.: 2:12-cv-02313-EFB
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) STIPULATION AND PROPOSED ORDER
) FOR AN EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that the time for Defendant to respond to Plaintiff’s Motion for Summary

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Judgment be extended 35 days to and including January 28, 2016. This is Defendant’s first

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request for an extension of time to respond to Plaintiff’s motion. Defense counsel needs the

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additional time to further review the file and prepare a response in this matter due to a heavy

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workload, including several other district court cases, despite due diligence.

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The parties further stipulate that the remaining dates in the Court’s Scheduling Order
shall be modified accordingly.
Defense counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: December 23, 2015

/s/ Lynn M. Harada for Peter Brixie*_
(*as authorized via email on 12/23/15)
PETER BRIXIE
Attorney for Plaintiff

Dated: December 23, 2015

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Lynn M. Harada
LYNN M. HARADA
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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APPROVED AND SO ORDERED.

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Dated: December 29, 2015.

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THE HONORABLE EDMUND F. BRENNAN
United States Magistrate Judge