Tunnell v. Commissioner of Social Security

Filing 13

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 12/11/2014 ORDERING the plaintiff to file a Motion for Summary Judgment by 2/9/2015; ORDERING the defendant to file a Reply Brief by 3/11/2015; ORDERING the plaintiff to file any response brief by 3/25/2015. (Michel, G)

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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Peter TUNNELL,
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Plaintiff,
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vs.
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Carolyn W. COLVIN, Acting
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Commissioner of Social Security,
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Defendant.
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Case No.: 2:14-cv-01334-AC
STIPULATION AND ORDER TO EXTEND
DUE DATE OF PLAINTIFF’S BRIEF IN
SUPPORT OF HIS MOTION FOR
SUMMARY JUDGMENT

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Plaintiff, by and through his attorney of record, and Defendant, by and through
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her attorney of record, hereby stipulate, subject to the approval of the Court, to a 60-day
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extension of time for Plaintiff’s counsel to file a brief in support of her Motion for
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Summary Judgment, in light of the following:
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1.

Plaintiff’s counsel is a sole practitioner and has other matters with

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approaching deadlines. The transcript in this proceeding is lengthy.
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Plaintiff’s counsel needs additional time to review the transcript and to
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write the Motion.
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Stipulation and Order of Extension of Time to File S/J, 2:14-cv-01334-AC - 1

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2.

Plaintiff’s counsel has emailed Armand Roth, Esq., defendant’s counsel.

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He has indicated that he is agreeable to a 60 day extension of time for

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counsel to prepare her brief.

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3.

Should the request be granted, Plaintiff’s brief will be due on February 09,

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2015, Defendant’s reply brief on March 11, 2015 and Plaintiff’s optional

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response brief on March 25, 2015.

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Respectfully submitted,

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Dated: December 10, 2014

/s/ Geri N. Kahn
GERI N. KAHN
Attorney for Plaintiff

Dated: December 10, 2014

/s/ Armand Roth
Armand Roth
Special Assistant United States Attorney
Attorney for Defendant

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ORDER
Pursuant to stipulation, IT IS SO ORDERED.

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Date: December 11, 2014

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Stipulation and Order of Extension of Time to File S/J, 2:14-cv-01334-AC - 2