Al-Bayati v. Colvin

Filing 12

STIPULATION and ORDER 10 for extension of time signed by Magistrate Judge Dale A. Drozd on 2/20/2015. Plaintiff's Brief will be due on 4/20/2015. Defendant's Reply Brief on 5/20/2015 and plaintiff's optional Response Brief on 6/9/2015. (Marciel, M)

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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
Boshra Al-Bayati

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Boshra AL-BAYATI,

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Plaintiff

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vs.

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No. 2-14-cv-02251-DAD
STIPULATION AND ORDER TO EXTEND
DUE DATE OF PLAINTIFF'S BRIEF IN
SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT

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.

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indicated that he is agreeable to a 60 day extension of time for counsel to prepare her

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

brief.
3.

Should the request be granted, Plaintiff’s brief will be due on April 20, 2015, Defendant’s
reply brief on May 20, 2015 and Plaintiff’s optional response brief on June 9, 2015.

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No. 2-14-cv-02251-DAD
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STIPULATION AND ORDER TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER
MOTION FOR SUMMARY JUDGMENT

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Respectfully submitted,
Dated: February 19, 2015

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

Dated: February 19, 2015

/s/ Theophous Reagans
THEOPHOUS REAGANS, ESQ.
Special Assistant United States Attorney
(*By email authorization on 02/19/2015)

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ORDER

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Pursuant to the parties’ stipulation, IT IS SO ORDERED.
Dated: February 20, 2015

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Ddad1\orders.soc sec
albayati2251.stip.eot.ord.docx

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No. 2-14-cv-02251-DAD
2
STIPULATION AND ORDER TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER
MOTION FOR SUMMARY JUDGMENT