King v. Colvin

Filing 15

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 12/29/15 ORDERING the court adopts the parties' stipulation as outlined above. Plaintiff's opening brief is now due on December 30, 2015. The Court's Scheduling Order 5 is modified accordingly. (Becknal, R)

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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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VALERIE JEAN KING,
Plaintiff,

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vs.

Case # 2:15-CV-01081-AC
STIPULATED MOTION AND ORDER FOR
EXTENSION OF TIME

CAROLYN COLVIN, Acting Commissioner
of Social Security,

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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 first extension of time to file Plaintiff’s
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opening brief.
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Counsel for the Plaintiff had to take an emergency flight to Mississippi to be with a dying
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family member and address her affairs before she passes. Counsel for the Plaintiff has no access
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to her files or laptop in her current location and is a solo practitioner that does not have
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additional attorneys to help with this caseload at this time. As a result, counsel for Plaintiff
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requires additional time to draft the opening brief. Plaintiff requests an extension of time to
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December 30, 2015.
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The parties stipulate that the Court’s Scheduling Order shall be modified accordingly.
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Dated November 21, 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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5

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Dated November 21, 2015:

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s/ KELSEY M. BROWN for Timothy Bolin
TIMOTHY BOLIN
(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 opening brief is

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now due on December 30, 2015. The Court’s Scheduling Order (Doc. 5) is modified

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accordingly.

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IT IS SO ORDERED.

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DATED: December 29, 2015

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