Brown v. Colvin

Filing 18

STIPULATION AND ORDER re 17 STIPULATION WITH PROPOSED ORDER for extension of time for plaintiff to file brief in support of Motion for Summary Judgment filed by Diane Yvonne Brown. Signed by Judge Edward M. Chen on 3/31/17. (bpf, COURT STAFF) (Filed on 3/31/2017)

Case 3:16-cv-04022-EMC Document 17 Filed 03/14/17 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 45-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.

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Counsel for Plaintiff has had additional surgery and anticipates returning to work full time
on March 23, 2017. She needs additional time to research and write the Motion.

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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 45 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 April 20, 2017, Defendant’s
reply brief on May 18, 2017, and Plaintiff’s optional response brief on June 1, 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 17 Filed 03/14/17 Page 2 of 2

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Respectfully submitted,
Dated: March 14, 2017

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

Dated: March 14, 2017

/s/ Jennifer Tarn
JENNIFER TARN
Special Assistant United States Attorney
(*By email authorization on March 14, 2017)

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.

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ER

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RT

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Edward M. Chen
United States M. Chen Judge
Magistrate
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e Edwar
Judg

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IT IS S

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3/31/17

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Dated:

UNIT
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S DISTRICT
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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]