Opinion
Case No. 11-0347 KJN
09-20-2011
VAN DUONG xxx-xx-8636 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 ELIZABETH BARRY Special Assistant United States Attorney Attorneys for Defendant
BESS M. BREWER, #100364
LAW OFFICE OF
BESS M. BREWER & ASSOCIATES
Attorneys for Plaintiff
STIPULATION AND 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 his summary judgment is hereby extended from September 20, 2011, to October 7, 2011. This extension is required due to Plaintiff's counsel's impacted briefing schedule which became further impacted due to the time she spent from September 13, 2011, through September 17, 2011, dealing with a family crisis. See, declaration of Bess M. Brewer
BESS M. BREWER
Attorney at Law
Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
ELIZABETH BARRY
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 his motion for summary judgment.
2. Plaintiff's brief is due September 20, 2011. Unfortunately, I was needed to help deal with the mental health crisis of a family member starting the evening of September 13, 2011, and extending through September 17, 2011. As a result, my briefing schedule has become even more impacted necessitating my request for an extension of time to file Ms. Duong's brief until October 7, 2011.
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.
ORDER
The stipulation of the parties is HEREBY APPROVED. Plaintiff shall have until October 7, 2011, to file a motion for summary judgment. The court's scheduling order is modified accordingly.
IT IS SO ORDERED.
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE