Opinion
Civil No. 4:12-cv-05291-DMR
03-27-2013
LATOYA DEANN JOHNSON, Plaintiff, v. MICHAEL J. ASTRUE, Commissioner of Social Security, Defendant.
RON S. HOCHBAUM Attorney for Plaintiff MELINDA L. HAAG United States Attorney PAUL SACHELARI Special Assistant United States Attorney Attorneys for Defendant
RON S. HOCHBAUM, CSBN 282344
Homeless Action Center
3126 Shattuck Avenue
Berkeley. CA 94705
(510) 540-0878 x 321 tel
(510) 540-0403 fax
rhochbaum@homelessactioncenter.org
Attorney for Plaintiff
STIPULATION AND PROPOSED ORDER TO EXTEND TIME
IT IS HEREBY STIPULATED by and between the parties, through their respective counsel of record, that the time for Plaintiff to file her Motion for Summary Judgment be extended from April 2, 2013 to May 2, 2013. This is Plaintiff's second request for an extension of time to file her Motion for Summary Judgment. Plaintiff needs the additional time to further review the documents submitted by Defendant and to prepare the Motion in this matter due to a heavy workload, despite due diligence. Counsel apologizes to the Court for any inconvenience caused by this delay.
Respectfully submitted,
____________________
RON S. HOCHBAUM
Attorney for Plaintiff
MELINDA L. HAAG
United States Attorney
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PAUL SACHELARI
Special Assistant United States Attorney
Attorneys for Defendant PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE