Opinion
CASE NO. 2:10-CV-03179-CMK
10-05-2011
KATHY LAUGHLIN 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 PETER THOMPSON Special Assistant United States Attorney Attorneys for Defendant
BESS M. BREWER, #100364
LAW OFFICE OF
BESS M. BREWER & ASSOCIATES
Attorneys for Plaintiff
STIPULATIONAND
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 to October 14, 2011. Plaintiff's brief was last due September 8, 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
PETER THOMPSON
Special Assistant United States Attorney
Attorneys for Defendant
DECLARATION
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 September 8, 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 can't realisticly file Ms. Laughlin's brief until October 14, 2011. I do not want to promise an earlier date that I can't meet.
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 29, 2011, in Sacramento, California.
BESS M. BREWER
ORDER
APPROVED AND SO ORDERED.
CRAIG M. KELLISON
UNITED STATES MAGISTRATE JUDGE