Azizi v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 4/3/2015 ORDERING that Plaintiff's brief is due on 4/16/2015, Defendant's reply brief on 5/18/2015 and Plaintiff's optional response brief on 6/1/2015. (Zignago, K.)

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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
FOURTH STIPULATION TO EXTEND
DUE DATE OF PLAINTIFF’S BRIEF IN
SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT; AND ORDER

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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 14-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’s father passed away on March 30, 2015, due to

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complications of Alzheimer’s disease. The last month has been a steady
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decline and counsel has been out of the office a great deal. Counsel is
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Jewish and is “sitting shiva” this week (a mourning period).
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Stipulation of Extension of Time to File S/J, 2:14-cv-01334-AC - 1

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2.

Counsel is aware that she has requested a number of extensions in this

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case and does not anticipate any further interruptions to her life that would

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prevent her from timely completing the brief.

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3.

Plaintiff’s counsel has spoken to counsel for the Commissioner. He has

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indicated that he is agreeable to a 14 -day extension of time for counsel to

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prepare her brief.

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4.

Should the request be granted, Plaintiff’s brief will be due on April 16,

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2015, Defendant’s reply brief on May 18, 2015 and Plaintiff’s optional

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response brief on June 1, 2015.

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Respectfully submitted,

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Dated: April 2, 2015

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

Dated: April 2, 2015

/s/ Peter Thompson for 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: April 3, 2015

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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