King v. Astrue

Filing 28

ORDER DISCHARGING OSC; ORDER EXTENDING TIME TO FILE MOTION re 25 Order to Show Cause, ***Deadlines terminated. 25 Order to Show Cause, 27 MOTION for Extension of Time to File Motion for Summary Judgment MOTION for Extension of Time to File Response/Reply Stipulation and proposed order filed by Shenita M. King. Motions due by 12/6/2010.. Signed by Judge Maria-Elena James on 10/20/2010. (mejlc1, COURT STAFF) (Filed on 10/20/2010)

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Geri N. Kahn, Esq., SBN 148536 400 Montgomery Street, Suite 810 San Francisco, CA 94104 Tel. [phone] Fax [phone] Email: [e-mail]

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

SHENITA M. KING, Plaintiff, vs. MICHALE J. ASTRUE, Commissioner of Social Security, Defendant.

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Case No.: No. 09-5322 MEJ STIPULATION TO EXTEND DUE DATE OF PLAINTIFF'S BRIEF IN SUPPORT OF HER MOTION FOR SUMMARY JUDGMENT; AND [PROPOSED ORDER]

Plaintiff, by and through her attorney of record, and Defendants, by and through their attorneys of record, hereby stipulate, subject to the approval of the Court, to a 90day extension of time for Plaintiff's counsel to file a brief in support of her Motion for Summary Judgment, in light of the following: 1. Plaintiff, Shenita King, retained counsel on September 6, 2010. Her new counsel did not represent her at any point in the administrative process and is generally unfamiliar with her case.

Stipulation of Extension of Time to File S/J, 09-5322 MEJ - 1

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2.

Plaintiff's counsel has spoken with Elizabeth Firer, Esq., defendant's counsel and she has indicated that she is agreeable to a 90 day extension of time for counsel to prepare her brief.

3.

Plaintiff's counsel has not yet had a chance to review the transcript thoroughly. She will need the extension of time to meet with Plaintiff more, to review the transcript and to prepare the motion for summary judgment.

4.

Should the request be granted, Plaintiff's brief will be due on December 6, 2010, Defendant's reply brief on January 5, 2011 and Plaintiff's response January on December 19, 2011. Respectfully submitted,

Dated: September 6, 2010

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

Dated: September 7, 2010

/s/Elizabeth Firer ELIZABETH FIRER Special Assistant United States Attorney Attorney for Defendants

ORDER The OSC is DISCHARGED. Pursuant to stipulation, IT IS SO ORDERED. October 20

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Date: September ___, 2010

Maria-Elena James United States Magistrate Judge

Stipulation of Extension of Time to File S/J, 09-5322 MEJ - 2