Opinion
Case No. 12-cv-02413-AC
12-11-2012
LISA ANN KNOX Plaintiff, v. MICHAEL J. ASTRUE Commissioner of Social Security of the United States of America, Defendant.
BESS M. BREWER, #100364 LAW OFFICE OF BESS M. BREWER & ASSOCIATES Attorneys for Plaintiff
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 Plaintiff's time to file her summary judgment is hereby extended from December 12, 2012, to January 18, 2012. Plaintiff's counsel received the record in the form of an encrypted disk from Ms. Knox's former counsel. She forwarded the disc to the local U.S. Attorney's office on December 3, 2012, for decrypting and was informed today that a newly formatted disc would be mailed out this week. Therefore, plaintiff's counsel needs an additional extension within which to file Ms. Knox's summary judgment motion. See, Declaration set forth below.
DECLARATION
1. I, Bess M. Brewer, am counsel for plaintiff in the above referenced case which originated out of the State of Washington. 2. I substituted in as counsel on the case October 11, 2012, and received the record in the form of a disc the second week of November. 3. When I attempted to open the disc on December 3, 2012, I realized a different encryption had been utilized and the disc could not be opened. That same day, I contacted Karen Clark with the Attorney General's office who indicated she would obtain a new disc and get it to me ASAP. 5. On December 10, 2012, I recontacted Karen Clark regarding the status of the disc and was informed that she had not been able to open the disc and had forwarded it to ODAR. She promised to contact ODAR for an update and just informed me that ODAR had promised that the reformatted disc would be mailed to her office this week. She would then forward the disc to me. 6. Given the fact that I do not have the record combined with the upcoming holidays, I require an additional extension until January 18, 2012, within which to complete Ms. Knox's summary judgment motion.
______________________
BESS M. BREWER
Attorney at Law
Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
Donna L. Calvert
Acting Regional Chief Counsel, Region IX
Social Security Administration
______________________
DANIEL TALBERT
Special Assistant United States Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED.
______________________
ALLISON CLAIRE
UNITED STATES MAGISTRATE JUDGE