Brown v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER signed by Magistrate Judge Edmund F. Brennan on 12/15/2014 ORDERING the defendanto to respond to the plaintiff's 16 Motion for Summary Judgment by 1/14/2015; MODIFYING the remaining dates in the Court's Scheduling Order accordingly. (Michel, G)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
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,
Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

) Case No.: 2:14-cv-00952-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 for 30 days until January 14, 2015. This is Defendant’s second request

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

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time to address the issues raised in Plaintiff’s brief due to a heavy workload, including several

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district court cases and a Ninth Circuit case, 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 12, 2014

/s/ Lynn M. Harada for Peter Brixie*____
(*as authorized via email on 12/11/14)
PETER BRIXIE
Attorney for Plaintiff

Dated: December 12, 2014

BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
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 15, 2014.