Opinion
CASE NO. 2:10-CV-02941-GGH (TEMP)
09-19-2011
KEITH SMITH 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 DAVID W. LERCH 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 his summary judgment is hereby extended to September 23, 2011. This extension is required due to Plaintiff's counsel's need to address a mental health crisis with a family member which began the evening of September 13, 2011, and extended through September 17, 2011. See, Declaration of Counsel.
BESS M. BREWER
Attorney at Law
Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
DAVID W. LERCH
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 was due September 15, 2011. Unfortunately, I was unable to complete his brief because I was needed to help deal with the mental health crisis of a family member.
3. At this time, I request until Friday, September 23, 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
APPROVED AND SO ORDERED.
Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE