Al-Bayati v. Colvin

Filing 14

STIPULATION AND ORDER signed by Magistrate Judge Dale A. Drozd on 4/21/2015 ORDERING the plaintiff to file a Motion for Summary Judgment by 6/4/2015; ORDERING the Commissioner of Social Security to respond to said motion by 7/6/2015; ORDERING the plaintiff to file an optional reply brief by 7/20/2015. (Michel, G.)

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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 45-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’s father passed away on March 30, 2015, due to complications of

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Alzheimer’s disease. The month prior to this was a steady decline in his health and

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counsel has been out of the office a great deal. Counsel has not had time to work on the

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brief.

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2.

Plaintiff’s counsel has spoken with Theophous Reagans, Esq., defendant’s counsel, and he
has indicated that he is agreeable to a 45 day extension of time for counsel to prepare her
brief.

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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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3.

Should the request be granted, Plaintiff’s brief will be due on June 4, 2015, Defendant’s
reply brief on July 6, 2015 and Plaintiff’s optional response brief on July 20, 2015.

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Respectfully submitted,

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Dated: April 20, 2015

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

Dated: April 20, 2015

/s/ Theophous Reagans
THEOPHOUS REAGANS, ESQ.
Special Assistant United States Attorney

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ORDER
Pursuant to the parties’ stipulation, IT IS SO ORDERED.
Dated: April 21, 2015

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Ddad1\orders.soc sec
albayati2251.stip.eot.ord2.docx

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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