Kane v. Commissioner of Social Security

Filing 12

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 4/16/15 re: 11 APPROVING and ORDERING Extension of Time for Plaintiff to file Summary Judgment motion. (Meuleman, A)

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BESS M. BREWER, #100364
LAW OFFICE OF
BESS M. BREWER & ASSOCIATES
P.O. Box 5088
Sacramento, CA 95817
Telephone: [phone]

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Attorneys for Plaintiff

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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MONIQUE R. KANE

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Plaintiff,

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v.

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CAROLYN W. COLVIN,
ACTING COMMISSIONER OF SSA

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Defendant.

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Case No. 14-2419 CKD
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STIPULATIONAND PROPOSED
ORDER EXTENDING PLAINTIFF=S
TIME TO FILE SUMMARY
JUDGMENT MOTION

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IT IS HEREBY STIPULATED by and between the parties, through their attorneys, that

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Plaintiff=s time to file her summary judgment motion is hereby extended from April 10, 2015, to April

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20, 2015, with all other deadlines extended accordingly. This extension is required due to counsel=s

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failure to re calendar the due date for Ms. Kane=s summary judgment motion. (See declaration.)

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I , Bess M. Brewer, Declare:
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I am an attorney licensed the practice law in California and am admitted

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to practice before this Court. I represent the plaintiff in the above

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referenced case.

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2.

Plaintiff=s motion for summary judgment was extended to April 10,

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2015, unfortunately, I failed to re calender the new due date. I just

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became aware of the oversight today.

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3.

I apologize to the Court for my failure to file Ms. Kanes= summary
judgment motion on time.

I declare under the penalty of perjury that the foregoing is true and correct to the best of my
knowledge, and that this declaration was executed on April 14, 2015. In Sacramento, California.

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/s/ Bess M. Brewer

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BESS M. BREWER

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Dated: April 14, 2015

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/s/Bess M. Brewer
BESS M. BREWER
Attorney at Law
Attorney for Plaintiff

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Dated: April 14, 2015
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Benjamin B. Wagner
United States Attorney
Donna L. Calvert
Regional Chief Counsel, Region IX
Social Security Administration
/s/Ann Lucille Maley
ANN LUCILLE MALEY
Special Assistant United States Attorney
Attorneys for Defendant

ORDER

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APPROVED AND SO ORDERED.
Dated: April 16, 2015

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CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE