O'Connor v. Commissioner of Social Security

Filing 16

STIPULATION AND ORDER EXTENDING PLAINTIFF'S TIME TO FILE MEMORANDUM IN SUPPORT OF SUMMARY JUDGMETN AND DECLARATION. Signed by Judge Joseph C. Spero on 12/22/09. (klh, COURT STAFF) (Filed on 12/22/2009)

Case3:09-cv-01508-JCS Document15

Filed12/21/09 Page1 of 3

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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 ELENA O'CONNOR 11 12 13 14 15 16 17 18 19 IT IS HEREBY STIPULATED by and between the parties, through their attorneys, and with the 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 December 21, 2009, to February 9, 2009. This is 22 plaintiff's first request for an extension of time and is required due to plaintiff's counsel's impacted 23 briefing schedule and the upcoming holidays. See, Declaration of Bess M. Brewer set forth below 24 25 /// 26 /// 27 /// 28 1 v. MICHAEL J. ASTRUE Commissioner of Social Security of the United States of America, Defendant. Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. CIV-09-1508 JCS

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

Case3:09-cv-01508-JCS Document15

Filed12/21/09 Page2 of 3

1 Dated: December 21, 2009 2 3 4 Dated: December 21, 2009 5 6 7 8 9 10 11 12

s/Bess M. Brewer BESS M. BREWER Attorney at Law Attorney for Plaintiff McGregor W. Scott United States Attorney /s/ Shea Lita Bond SHEA LITA BOND Special Assistant U.S. Attorney Social Security Administration Attorney for Defendant DECLARATION OF BESS M. BREWER

DECLARATION OF BESS M. BREWER

13 I, Bess M. Brewer, Declare: 14 1. I represent the plaintiff, Ms. O'Connor, in the above referenced case pending in this

15 court and submit this declaration in support of plaintiff's stipulated request for an extension of time to 16 file her motion for summary judgment. 17 18 19 20 21 22 23 3. This is my first request for an extension of time to file Ms. O'Connor's summary judgment and the granting of this stipulated request will not have an appreciable effect on the briefing of this case. I declare under the penalty of perjury that the foregoing is true and correct to the best 2. Due to the upcoming holidays and my extremely busy briefing schedule, I will require

additional time to complete Ms. O'Connor's Motion for Summary Judgment and Memorandum.

24 of my knowledge, and that this declaration was executed on December 21, 2009, in Sacramento, 25 California. 26 27 28 2 /s/ Bess M. Brewer BESS M. BREWER

Case3:09-cv-01508-JCS Document15

Filed12/21/09 Page3 of 3

1 2 3 APPROVED AND SO ORDERED. 4 5 6 DATED: 12/22/09 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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