Clark v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 9/28/11: Plaintiff's time to file his summary judgment is hereby extended from September 27, 2011, to October 6, 2011. (Kaminski, H)

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BESS M. BREWER, #100364
LAW OFFICE OF
BESS M. BREWER & ASSOCIATES
P.O. Box 5088
Sacramento, CA 95817
Telephone: [phone]

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Attorneys for Plaintiff

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IN THE UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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LARRY CLARK

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Plaintiff,
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v.
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MICHAEL J. ASTRUE
Commissioner of Social Security
of the United States of America,

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Defendant.
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CASE NO. 2:10-CV-02863-GGH
STIPULATIONAND PROPOSED
ORDER EXTENDING PLAINTIFF’S
TIME TO FILE SUMMARY
JUDGEMENT MOTION AND
DECLARATION OF COUNSEL

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IT IS HEREBY STIPULATED by and between the parties, through their attorneys, that the

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Plaintiff’s time to file his summary judgment is hereby extended from September 27, 2011, to October

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6, 2011. This short additional extension is required due to Plaintiff’s counsel’s impacted briefing

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schedule. Counsel has another brief today which takes priority, as well as five additional briefs which

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must be filed between September 27, 2011, and October 5, 2011. See, Declaration of Counsel.

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/s/Bess M. Brewer
BESS M. BREWER
Attorney at Law

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Attorney for Plaintiff

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Dated: September 27, 2011

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Dated: September 27, 2011

Benjamin B. Wagner

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United States Attorney
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/s/ Jacob Mikow
JACOB MIKOW
Special Assistant United States Attorney
Attorneys for Defendant

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DECLARATION OF BESS M. BREWER

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I, Bess M. Brewer, Declare:
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to practice before this Court. I represent the plaintiff in the above

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referenced case and submit this declaration in support of his request for

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I am an attorney licensed to practice law in California and am admitted

more time to file his summary judgment motion.
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Plaintiff’s motion for summary judgment is currently due today,

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September 27, 2011. However, I have another brief due today in
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Swortfiguer v. Astrue, CIV-10-1835 GSA which must be filed as well as
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five other briefs that must be filed between September 28, 2011, and
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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.
/s/ Bess M. Brewer

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BESS M. BREWER
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As this is plaintiff’s third request, there shall be no further extensions.

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ORDER

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APPROVED AND SO ORDERED.
DATED: September 28, 2011

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/s/ Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE

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GGH:076/Clark extension to October 6.wpd

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