Opinion
CASE NO. 2:10-CV-02863-GGH
09-28-2011
BESS M. BREWER Attorney at Law Attorney for Plaintiff Benjamin B. Wagner United States Attorney JACOB MIKOW 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 AND DECLARATION OF COUNSEL
IT IS HEREBY STIPULATED by and between the parties, through their attorneys, that the Plaintiff's time to file his summary judgment is hereby extended from September 27, 2011, to October 6, 2011. This short additional extension is required due to Plaintiff's counsel's impacted briefing schedule. Counsel has another brief today which takes priority, as well as five additional briefs which must be filed between September 27, 2011, and October 5, 2011. See, Declaration of Counsel.
BESS M. BREWER
Attorney at Law
Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
JACOB MIKOW
Special Assistant United States Attorney
Attorneys for Defendant
DECLARATION OF BESS M. BREWER
I, Bess M. Brewer, Declare:
1. I am an attorney licensed to practice law in California and am admitted to practice before this Court. I represent the plaintiff in the above referenced case and submit this declaration in support of his request for more time to file his summary judgment motion.
2. Plaintiff's motion for summary judgment is currently due today, September 27, 2011. However, I have another brief due today in Swortfiguer v. Astrue, CIV-10-1835 GSA which must be filed as well as five other briefs that must be filed between September 28, 2011, and October 6, 2011. Consequently, I can't realistically file Mr. Clark's brief before October 6, 2011, and do not want to promise a date I can't deliver.
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 27, 2011, in Sacramento, California.
BESS M. BREWER As this is plaintiff's third request, there shall be no further extensions.
ORDER
APPROVED AND SO ORDERED.
Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE
GGH:076/Clark extension to October 6.wpd