Brown v. Colvin

Filing 20

STIPULATION AND ORDER re 19 STIPULATION WITH PROPOSED ORDER for 11-day extension of time to file Motion for Summary Judgment filed by Diane Yvonne Brown. Signed by Judge Edward M. Chen on 4/25/17. (bpfS, COURT STAFF) (Filed on 4/25/2017)

Case 3:16-cv-04022-EMC Document 19 Filed 04/20/17 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 11-Day 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 11-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 has been working diligently on the brief. She has had some other

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pressing deadlines in her immigration practice and has had to take time off from the

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Motion to address them. She anticipates no further delays to completing 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 an 11 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 May 1, 2017, Defendant’s
reply brief on May 29, 2017, and Plaintiff’s optional response brief on June 12, 2017.

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Case No. 16-cv-04022-EMC
1
STIPULATION OF 11-DAY EXTENSION OF TIME FOR PLAINTIFF TO FILE BRIEF IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT; [PROPOSED ORDER]

Case 3:16-cv-04022-EMC Document 19 Filed 04/20/17 Page 2 of 2

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Respectfully submitted,
Dated: April 20, 2017

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

Dated: April 20, 2017

/s/ Jennifer Tarn
JENNIFER TARN
Special Assistant United States Attorney
(*By email authorization on April 20, 2017)

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.

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United States Magistrate Judge
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M. Che
Edward
Judge

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RDERE
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Edward M. Chen

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April 25, 2017

UNIT
ED

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Dated:

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Case No. 16-cv-04022-EMC
2
STIPULATION OF 11-DAY EXTENSION OF TIME FOR PLAINTIFF TO FILE BRIEF IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT; [PROPOSED ORDER]