Guitierrez v. Commissioner of Social Security Administration

Filing 16

STIPULATION AND ORDER EXTENDING TIME TO FILE SUMMARY JUDGMENT. Signed by Judge Alsup on November 10, 2009. (whalc1, COURT STAFF) (Filed on 11/10/2009)

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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 GEORGINA GUITIERREZ 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-09-2323 WHA

[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 November 9, 2009, to December 16, 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. See, Declaration of Bess M. Brewer set forth below 24 25 / / / 26 / / / 27 / / / 28 1

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1 Dated: November 6, 2009 2 3 4 Dated: November 9, 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/ Theophous Reagans THEOPHOUS REAGANS 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. Guitterrez, 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 up. Consequently, I will require additional time to complete Ms. Guiterrez's Motion for Summary 20 Judgment and Memorandum. 21 22 3. This is my first request for an extension of time to file Ms. Guitterrez's summary 2. I have an extremely busy briefing schedule which became even more impacted when I

was out sick for 7 days during August. I fell behind on my briefing and am still struggling to catch-

23 judgment and the granting of this stipulated request will not have an appreciable effect on the briefing 24 of this case. 25 I declare under the penalty of perjury that the foregoing is true and correct to the best

26 of my knowledge, and that this declaration was executed on November 6, 2009, in Sacramento, 27 California. 28 2 /s/ Bess M. Brewer BESS M. BREWER

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

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