Garcia v. Astrue

Filing 15

STIPULATION AND ORDER extending time to 2/10/2009 for plaintiff to file motion for summary judgment; Signed by Judge Marilyn Hall Patel on 1/7/2008. (awb, COURT-STAFF) (Filed on 1/8/2009)

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BESS M. BREWER, #100364 LAW OFFICE OF BESS M. BREWER & ASSOCIATES P.O. BOX 5088 Sacramento, CA 95817 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Plaintiff

6 7 IN THE UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 10 JOSE DE LA LUZ GARCIA 11 12 Plaintiff, 13 v. 14 MICHAEL J. ASTRUE 15 Commissioner of Social Security of the United States of America, 16 Defendant. 17 18 19 IT IS HEREBY STIPULATED by and between the parties, through their attorneys, and with the ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. CIV-08-3833 MHP

[PROPOSED] STIPULATION AND ORDER EXTENDING PLAINTIFF'S TIME TO FILE MEMORANDUM IN SUPPORT OF SUMMARY JUDGMENT AND DECLARATION

20 permission of the Court as evidenced below, that the Plaintiff's time to file the summary judgment in this 21 case is hereby extended from its current due date of January 5, 2009, to February 10, 2009. This is 22 plaintiff's first request for an extension of time and is required due the holidays and plaintiff's counsel's 23 extremely heavy case load. See, Declaration of Bess M. Brewer set forth below 24 25 / / / 26 / / / 27 / / / 28 1

1 Dated: January 5, 2009 2 3 4 Dated: January 5, 2009 5 6 7 8 9 10 11

/s/Bess M. Brewer BESS M. BREWER Attorney at Law Attorney for Plaintiff McGregor W. Scott United States Attorney /s/ Jacqueline Forslud JACQUELINE FORSLUND Special Assistant U.S. Attorney Social Security Administration Attorney for Defendant DECLARATION OF BESS M. BREWER

12 DECLARATION OF BESS M. BREWER 13 14 15 16 17 18 1. I represent Mr. Garcia in Case No. CIV-08-3833 MHP 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. I was out of the office on vacation for the holidays and will require additional time to I, Bess M. Brewer, Declare:

19 complete Mr. Garcia's Motion for Summary Judgment and Memorandum. 20 3. This is my first request for an extension of time to file Mr. Garcia's summary

21 judgment and the granting of this stipulated request will not have an appreciable effect on the briefing 22 of this case. 23 I declare under the penalty of perjury that the foregoing is true and correct to the best 24 of my knowledge, and that this declaration was executed on January 5, 2009, in Sacramento, 25 California. 26 27 28 2 /s/ Bess M. Brewer BESS M. BREWER

1 2 3 APPROVED AND SO ORDERED. 4 5 6 DATED: 1/7/2009 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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