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)

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Case 3:16-cv-04022-EMC Document 14 Filed 01/04/17 Page 1 of 2 1 2 3 4 5 Geri N. Kahn (State Bar Number 148536) Law Office of Geri N. Kahn 465 California Street, Suite 609 San Francisco, CA 94104 Tel. (415) 397-5446 Fax (800) 375-5956 Attorneys for Plaintiff Diane Yvonne Brown 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE NORTHERN DISTRICT OF CALIFORNIA 10 11 Diane Yvonne Brown, 12 Plaintiff, 13 vs. 14 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, 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. Counsel for Plaintiff is recovering from surgery and has only returned full time to work 21 yesterday. She is a sole practitioner and has other matters with approaching deadlines. 22 She needs additional time to research and write the Motion. 23 2. Plaintiff’s counsel has emailed, Jennifer Tarn, Esq., defendant’s counsel. Ms. Tarn has 24 indicated that she is agreeable to a 60 day extension of time for counsel to prepare her 25 brief. 26 27 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. 28 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 1 2 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) 3 4 5 10 11 12 16 . Chen ward M udge Ed J Edward M. Chen ER United States Magistrate Judge C H 15 RT 14 1/10/17 DERED O OR IT IS S NO 13 Dated: RT U O S Pursuant to stipulation, IT IS SO ORDERED. S DISTRICT TE C TA R NIA 9 FO ORDER A 8 LI 7 UNIT ED 6 N F D IS T IC T O R 17 18 19 20 21 22 23 24 25 26 27 28 Case No. 16-cv-04022-EMC 2 STIPULATION OF EXTENSION OF TIME FOR PLAINTIFF TO FILE BRIEF IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT; [PROPOSED ORDER]

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