Brown v. Colvin

Filing 15

STIPULATION AND ORDER EXTENDING TIME TO FILE MSJ. Signed by Judge Edward M. Chen on 1/10/17. (bpfS, COURT STAFF) (Filed on 1/10/2017)

Case 3:16-cv-04022-EMC Document 14 Filed 01/04/17 Page 1 of 2

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Geri N. Kahn (State Bar Number 148536)
[e-mail]
Law Office of Geri N. Kahn
465 California Street, Suite 609
San Francisco, CA 94104
Tel. [phone]
Fax [phone]
Attorneys for Plaintiff
Diane Yvonne Brown

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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Diane Yvonne Brown,

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Plaintiff,

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vs.

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Case No. 16-cv-04022-EMC
Stipulation of Extension of Time for Plaintiff to
file brief in support of Motion for Summary
Judgment; [Proposed order]

Carolyn W. Colvin, Acting Commissioner of Social
Security Administration,

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

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

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

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1.

Counsel for Plaintiff is recovering from surgery and has only returned full time to work

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yesterday. She is a sole practitioner and has other matters with approaching deadlines.

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She needs additional time to research and write the Motion.

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2.

Plaintiff’s counsel has emailed, Jennifer Tarn, Esq., defendant’s counsel. Ms. Tarn has

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indicated that she is agreeable to a 60 day extension of time for counsel to prepare her

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brief.

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3.

Should the request be granted, Plaintiff’s brief will be due on March 6, 2017, Defendant’s
reply brief on April 5, 2017, and Plaintiff’s optional response brief on April 20, 2017.

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Case No. 16-cv-04022-EMC
1
STIPULATION OF EXTENSION OF TIME FOR PLAINTIFF TO FILE BRIEF IN SUPPORT OF MOTION
FOR SUMMARY JUDGMENT; [PROPOSED ORDER]

Case 3:16-cv-04022-EMC Document 14 Filed 01/04/17 Page 2 of 2

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Respectfully submitted,
Dated: January 4, 2017

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

Dated: January 4, 2017

/s/ Jennifer Tarn
JENNIFER TARN
Special Assistant United States Attorney
(*By email authorization on January 4, 2017)

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. Chen

ward M
udge Ed

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Edward M. Chen
ER
United States Magistrate Judge
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RT

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1/10/17

DERED

O OR
IT IS S

NO

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Dated:

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Pursuant to stipulation, IT IS SO ORDERED.

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FO

ORDER

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UNIT
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Case No. 16-cv-04022-EMC
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STIPULATION OF EXTENSION OF TIME FOR PLAINTIFF TO FILE BRIEF IN SUPPORT OF MOTION
FOR SUMMARY JUDGMENT; [PROPOSED ORDER]