Moore v. Asture

Filing 18

STIPULATION AND ORDER re 16 Stipulation filed by Steven Moore. Signed by Judge Paul S. Grewal on 9/16/2011. (psglc2, COURT STAFF) (Filed on 9/19/2011)

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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]

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Attorneys for Plaintiff
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IN THE UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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STEVEN MOORE
xxx-xx-5648

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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. 11-CIV-1905 PSG

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

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

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permission of the Court as evidenced below, that the Plaintiff’s time to file the summary judgment in

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this case is hereby extended to October 25, 2011. This is plaintiff’s first request for an extension of time

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and is required due to plaintiff’s counsel’s impacted briefing schedule. See, Declaration of Bess M.

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Brewer set forth below

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///

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///

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///

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

Dated: September 12, 2011

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Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
/s/ David W. Lerch
DAVID W. LERCH
Special Assistant U.S. Attorney
Attorney for Defendant

Dated: September 12, 2011
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DECLARATION OF BESS M. BREWER

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DECLARATION OF BESS M. BREWER

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I, Bess M. Brewer, Declare:

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1.

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

this declaration in support of plaintiff’s stipulated request for an extension of time to file her motion
for summary judgment.
2.

Plaintiff’s summary judgement was first due September 6, 2011, but I accidentally

calendared it for September 12, 2011, which I just realized today when preparing this extension.
However, due to my extremely busy briefing schedule and need to give older cases briefing priority, I

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will require additional time to complete Mr. Moore’s Motion for Summary Judgment and
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Memorandum.
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3.

This is my first request for an extension of time to file Mr. Moore’s summary

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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

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of my knowledge, and that this declaration was executed on September 12, 2011, in Sacramento,
California.

/s/ Bess M. Brewer
BESS M. BREWER

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ORDER

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APPROVED AND SO ORDERED.

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DATED:
MAGISTRATE JUDGE PAUL SINGH

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