Hives v. Commissioner of Social Security

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 7/2/15. Pursuant to 12 Stipulation IT IS SO ORDERED. No further extensions of time will be granted to plaintiff. (Meuleman, A)

1
2
3
4
5

Geri N. Kahn (State Bar Number 148536)
[e-mail]
Law Office of Geri N. Kahn
465 California Street, Suite 609
San Francisco, CA 94104
[phone]
[phone]
Attorney for Plaintiff
Stephanie Hives

6
7
IN THE UNITED STATES DISTRICT COURT
8
FOR THE EASTERN DISTRICT OF CALIFORNIA
9
10
11

Stephanie Hives,

12

Plaintiff

13

vs.

14

Case No. 2:14-cv-02953-CKD
STIPULATION TO EXTEND DUE DATE OF
PLAINTIFF'S BRIEF IN SUPPORT OF HER
MOTION FOR SUMMARY JUDGMENT AND
ORDER

Carolyn W. Colvin, Acting Commissioner of Social
Security

15
Defendant.
16
17

Plaintiff, by and through her attorney of record, and Defendant, by and through her attorney of

18

record, hereby stipulate, subject to the approval of the Court, to a 60-day extension of time for Plaintiff’s

19

counsel to file a brief in support of her Motion for Summary Judgment, in light of the following:

20

1.

Plaintiff’s counsel has not had time to complete the brief. She is moving to a new office

21

in San Francisco tomorrow and the search for the office space, the move and the planning

22

associated with it has taken longer than she anticipated.

23

2.

24
25
26
27

Plaintiff’s counsel has emailed counsel for the commissioner and defendant’s counsel is
agreeable to a 60 day extension of time for Plaintiff to prepare her brief.

3.

Should the request be granted, Plaintiff’s brief will be due on August 31, 2015,
Defendant’s reply brief on September 30, 2015 and Plaintiff’s optional response brief on
October 21, 2015.

28
30
31

Case No. 2:14-cv-02953-CKD
1
STIPULATION TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT AND ORDER

1
2
3

Respectfully submitted,
Dated: June 30, 2015

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

Dated: June 30, 2015

/s/ Asim Modi
Asim Modi
Special Assistant United States Attorney
(*By email authorization from Cheryl Jenkins, Esq.
on 06/30/2015)

4
5
6
7
8
9
10
11
12
13

ORDER

14

Pursuant to stipulation, IT IS SO ORDERED.

15

No further extensions of time will be granted to plaintiff.

16
17
18

Dated: July 2, 2015

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

19
20
21
22
23
24
25
26
27
28
30
31

Case No. 2:14-cv-02953-CKD
2
STIPULATION TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER MOTION FOR
SUMMARY JUDGMENT AND ORDER