Laughlin v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 10/05/11 ORDERING that plf's time to file her Motion for Summary Judgment is EXTENDED to 10/14/11. (Benson, A.)

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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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KATHY LAUGHLIN

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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-03179-CMK
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 to October 14, 2011. Plaintiff’s brief

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was last due September 8, 2011, but was not timely filed due to counsel’s inadvertent failure to calendar

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the date the motion was due. See, Declaration of Bess M. Brewer. This extension is required due to

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counsel’s oversight and impacted briefing schedule.

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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 29, 2011

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Dated: September 29, 2011

Benjamin B. Wagner

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United States Attorney
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/s/ Peter Thompson
PETER THOMPSON
Special Assistant United States Attorney
Attorneys for Defendant

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DECLARATION

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declaration in support of plaintiff’s stipulated request for an extension of time to file her motion for
summary judgment.

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I represent the plaintiff in the above referenced case pending in this court and submit this

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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.
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Given my briefing schedule, I can’t realisticly file Ms. Laughlin’s brief until October 14,

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2011. I do not want to promise an earlier date that I can’t meet.
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I declare under the penalty of perjury that the foregoing is true and correct to the best of
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my knowledge, and that this declaration was executed on September 29, 2011, in Sacramento,
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California.
/s/Bess M. Brewer

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BESS M. BREWER

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ORDER
APPROVED AND SO ORDERED.

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DATED: October 5, 2011
______________________________________
CRAIG M. KELLISON
UNITED STATES MAGISTRATE JUDGE

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