Kirk v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 6/12/2014 re: 14 Stipulation and Proposed Order ORDERING Plaintiff, Vonda K. Kirk, shall have up to and including July 25, 2014, to file a Motion for Summary Judgment. (Waggoner, D)

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BARBARA M. RIZZO (CSBN 172999)
Attorney At Law
P. O. Box 15
Moss Beach, CA 94038
Telephone: [phone]
Fax: [phone]
E-Mail: [e-mail]

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Attorney for Plaintiff Vonda K. Kirk

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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____________________________________
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Plaintiff,
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v.
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CAROLYN W. COLVIN,
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Commissioner of Social
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Security
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Defendant.
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____________________________________)
VONDA K. KIRK,

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Case No.: 13-CV-02571 EFB
STIPULATION AND [PROPOSED] ORDER
FOR EXTENSION OF TIME

IT IS HEREBY STIPULATED by the undersigned for the respective parties,

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subject to the approval of the Court, that the Plaintiff, Vonda K. Kirk, have

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a 28-day extension of time in which to file a Motion for Summary Judgment

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Motion, up to and including July 25, 2014.

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because the undersigned counsel for the Plaintiff is in the process of

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relocating her home and office.

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in this Social Security case, Defendant's Response to the Plaintiff's Motion

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for Summary Judgment is due 30 days after service of the Motion for Summary

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Judgment.

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after service of Defendant's Opposition.

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This extension is being sought

In keeping with the initial scheduling order

Plaintiff's Reply to the Defendant’s Opposition is due 21 days

Plaintiff respectfully requests that the Court approve this stipulation
for a 28-day extension of time for Plaintiff to file a Motion for Summary

STIPULATION AND ORDER FOR TIME EXTENSION
13-CV-2571 EFB

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Judgment until July 25, 2014.

This is the first extension of time that

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Plaintiff has requested in this case.

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Respectfully submitted,
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Dated:

June 11, 2014

Dated:

June 11, 2014

“/s/ Theophous Reagans”
(As authorized via e-mail)
THEOPHOUS REAGANS
Special Assistant United States Attorney
Attorney for Defendant

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By:

“/s/ Barbara M. Rizzo”
BARBARA M. RIZZO
Attorney for Plaintiff

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IT IS ORDERED that Plaintiff, Vonda K. Kirk, shall have up to and
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including July 25, 2014, to file a Motion for Summary Judgment.
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Dated:

June 12, 2014.

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STIPULATION AND ORDER FOR TIME EXTENSION2
13-CV-2571 EFB