Mejia v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 12/31/15: Plaintiff's motion for summary judgment is due on January 8, 2015. 16 Order to Show Cause is discharged. (Kaminski, H)

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KELSEY BROWN, CA #263109
Mackenzie Legal, PLLC
2529 Cliffside Ln NW, H-102
Gig Harbor, WA 98335
Phone: [phone]
Email: [e-mail]

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Attorney for Plaintiff
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACREMENTO DIVISION

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RUBEN MEJIA,
Plaintiff,

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Case # 2:15-CV-00707-EFB
STIPULATED MOTION AND ORDER FOR
EXTENSION OF TIME

vs.
COMMISSIONER OF SOCIAL SECURITY
Defendant.

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The parties hereby stipulate by counsel, with the Court’s approval as indicated by

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issuance of the attached Order, that Plaintiff shall have a second extension of time to file

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Plaintiff’s opening brief.

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Counsel for the Plaintiff had to take an emergency flight to Mississippi to be with my

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dying grandmother, to provide end of life care and address her affairs before and after she

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passes. Counsel for the Plaintiff has limited access to her files or laptop in her current location

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and is a solo practitioner that does not have additional attorneys to help with this caseload at this

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Page 1

MOTION
[2:15-CV-00707-EFB]

Mackenzie Legal, PLLC
2529 Cliffside Ln NW, H-102
Gig Harbor, WA 98335
Phone: [phone]

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time. As a result, counsel for Plaintiff requires additional time to draft the opening brief. Plaintiff
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requests an extension of time to January 8, 2015.
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The parties stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Dated November 9, 2015:

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/s/ Kelsey M Brown
KELSEY MACKENZIE BROWN CA #263109
Mackenzie Legal, PLLC
2529 Cliffside Ln NW, H-102
Gig Harbor, WA 98335
Phone: [phone]

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Attorney for Plaintiff

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Dated November 9, 2015:

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s/ KELSEY M. BROWN for Heather Moss
HEATHER MOSS
(per e-mail authorization)
Special Assistant U.S. Attorney
Office of the General Counsel

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Of Attorneys for Defendant

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ORDER

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The Court adopts the parties’ stipulation as outlined above. Plaintiff’s motion for

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summary judgment opening brief is now due on January 8, 2015. The Court’s Scheduling Order

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(Doc. 6) is modified accordingly.

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grandmother, the court’s December 29, 2015 order to show cause is discharged and no sanctions

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are imposed.

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IT IS SO ORDERED this 31st day of December, 2015.

In light of counsel’s representations regarding her

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Page 2

MOTION
[2:15-CV-00707-EFB]

Mackenzie Legal, PLLC
2529 Cliffside Ln NW, H-102
Gig Harbor, WA 98335
Phone: [phone]