Lothian v. Colvin

Filing 17

STIPULATION AND ORDER re 16 For Extension of Time to File Summary Judgment. Signed by Magistrate Judge Howard R. Lloyd on 1/7/2014. (hrllc1, COURT STAFF) (Filed on 1/7/2014)

*E-Filed: January 7, 2014*
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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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JANET LOTHIAN
xxx-xx-7174

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Plaintiff,

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v.

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COMMISSIONER OF SSA
Defendant.

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Case No. 13-cv-02997 HRL

[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

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

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judgment in this case is hereby extended from January 6, 2014, to January 14, 2014, with all other

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due dates adjusted accordingly. This short additional extension of time is required due plaintiff’s

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counsel’s impacted briefing schedule and need to complete an older brief due the same day. See,

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Declaration of Bess M. Brewer set forth below.

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

Dated: January 6, 2014

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Attorney for Plaintiff
Benjamin B. Wagner
United States Attorney
/s/ Patrick Snyder
PATRICK SNYDER

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Dated: January 6, 2014

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Special Assistant U.S. Attorney
Attorney for Defendant

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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

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this declaration in support of plaintiff’s stipulated request for an extension of time to file his motion

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for summary judgment.

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2.

Due to my briefing schedule, I need an additional week to complete Ms. Lothian’s

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Motion for Summary Judgment and Memorandum. At the time of the first request, I felt I would be

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able to complete both briefs scheduled for January 6, 2014. Unfortunately, I am unable to do so and

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need additional time to complete Ms. Lothian’s MSJ.

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3.

This short additional extension of time to file Ms. Lothian’s summary judgment will

not have an appreciable effect on the briefing of this case.

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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 January 6, 2014, in Sacramento,
California.

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/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: January 7, 2014
HONORABLE HOWARD R. LLOYD

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