Opinion
Case No. CIV-11-0654 GGH (TEMP)
09-22-2011
CHOU YANG Plaintiff, v. MICHAEL J. ASTRUE Commissioner of Social Security of the United States of America, Defendant.
BESS M. BREWER Attorney at Law Attorney for Plaintiff Benjamin B. Wagner United States Attorney TOVA D. WOLKING Special Assistant United States Attorney Attorneys for Defendant
BESS M. BREWER, #100364
LAW OFFICE OF
BESS M. BREWER & ASSOCIATES
Attorneys for Plaintiff
STIPULATIONAND PROPOSED ORDER EXTENDING PLAINTIFF'S
TIME TO FILE SUMMARY JUDGEMENT MOTION
IT IS HEREBY STIPULATED by and between the parties, through their attorneys, that the Plaintiff's time to file the summary judgment is hereby extended to October 21, 2011. Plaintiff's motion was originally due August 29, 2011, but was not timely filed due to counsel's inadvertent failure to calendar the date the motion was due. See, Declaration of Bess M. Brewer. This extension is required due to counsel's oversight and impacted briefing schedule.
BESS M. BREWER
Attorney at Law
Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
TOVA D. WOLKING
Special Assistant United States Attorney
Attorneys for Defendant
DECLARATION OF BESS M. BREWER
1. I represent the plaintiff in the above referenced case pending in this court and submit this declaration in support of plaintiff's stipulated request for an extension of time to file her motion for summary judgment.
2. Plaintiff's brief was due August 29, 2011. Unfortunately, I failed to calendar the date. This oversight was just brought to my attention and I apologize for my failure to properly calendar the date.
3. Given my briefing schedule, I will need until October 21, 2011, within which to file plaintiff's summary judgment motion.
I declare under the penalty of perjury that the foregoing is true and correct to the best of my knowledge, and that this declaration was executed on September 19, 2011, in Sacramento, California.
BESS M. BREWER
ORDER
No further extension are authorized. APPROVED AND SO ORDERED.
Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE