Azizi v. Commissioner of Social Security

Filing 16

SECOND STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 2/26/2015 ORDERING 15 Plaintiff's Brief due 3/26/2015; Defendant's reply due by 4/27/2015; and Plaintiff's optional response brief by by 5/18/2015. (Reader, L) Modified on 2/26/2015 (Reader, L).

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Geri N. Kahn, Esq., SBN 148536
400 Montgomery Street, Suite 810
San Francisco, CA 94104
Tel. [phone]
Fax [phone]
Email: [e-mail]

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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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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-01693-CKD
SECOND STIPULATION TO EXTEND
DUE DATE OF PLAINTIFF’S BRIEF IN
SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT

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Plaintiff, by and through her 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 30-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 has been actively working on the Motion for Summary

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Judgment. Unfortunately her legal assistant recently left her job and
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counsel is having to spend time on administrative tasks as well as
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interviewing potential applicants for a job. Counsel has been unable to
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complete the brief.
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Stipulation of Extension of Time to File S/J, 2:14-cv-01334-AC - 1

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2.

Plaintiff’s counsel has emailed Theophous Reagans, Esq., defendant’s

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counsel. He has indicated that he is agreeable to a 30 day extension of

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time for counsel to prepare her brief.

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3.

Should the request be granted, Plaintiff’s brief will be due on March 26,

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

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response brief on May 18, 2015.

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Respectfully submitted,

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Dated: February 24, 2015

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

Dated: February 24, 2015

/s/ Theophous Reagans
Theophous H. Reagans
Special Assistant United States Attorney
Attorney for Defendant

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ORDER
Pursuant to stipulation, IT IS SO ORDERED.

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Dated: February 26, 2015

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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