Azizi v. Commissioner of Social Security

Filing 14

STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on January 13, 2015 GRANTING Plaintiffs request 13 to extend the due date for a brief in support of Motion for Summary Judgment. Plaintiffs brief is due on February 25, 2015; Defendants reply brief on March 27, 2015, and Plaintiffs optional response brief on April 17, 2015. (Rivas, A)

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Geri N. Kahn (CA State Bar Number 148536)
[e-mail]
Law Office of Geri N. Kahn
400 Montgomery Street, Suite 810
San Francisco, CA 94104
Tel. [phone], ext. 302
Fax [phone]
Attorney for Plaintiff
Sohaila Azizi

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Sohaila AZIZI,

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Plaintiff

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vs.

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Case No. 2:14-CV-01693-CKD
STIPULATION TO EXTEND DUE DATE OF
PLAINTIFF'S BRIEF IN SUPPORT OF HER
MOTION FOR SUMMARY JUDGMENT;
AND ORDER

Carolyn W. Colvin, Acting Commissioner of Social
Security,

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Defendant
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Plaintiff, by and through her attorney of record, and Defendant, by and through her attorney of

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record, hereby stipulate, subject to the approval of the Court, to a 60-day extension of time for Plaintiff’s

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counsel to file a brief in support of her Motion for Summary Judgment, in light of the following:

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1.

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

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The transcript in this proceeding is lengthy. Plaintiff’s counsel needs additional time to

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review the transcript and to write the Motion.

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2.

Plaintiff’s counsel has emailed Theophous Reagans, Esq., defendant’s counsel. Special
Assistant U.S. Attorney, Donna W. Anderson, on behalf of Theophous Reagans has
indicated that she is agreeable to a 60 day extension of time for counsel to prepare her
brief.

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Case No. 2:14-CV-01693-CKD
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STIPULATION TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT; AND ORDER

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3.

Should the request be granted, Plaintiff’s brief will be due on February 25, 2015,

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Defendant’s reply brief on March 27, 2015 and Plaintiff’s optional response brief on April

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17, 2015.

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Respectfully submitted,
Dated: December 23, 2014

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

Dated: December 23, 2014

/s/ Donna W. Anderson for*
THEOPHOUS REAGANS
Special Assistant United States Attorney
(*By email authorization from SAUSA
D.W. Anderson on 12/23/14)

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ORDER
Pursuant to stipulation, IT IS SO ORDERED.

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Dated: January 13, 2015

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Case No. 2:14-CV-01693-CKD
2
STIPULATION TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT; AND ORDER