STIPULATION AND PROPOSED ORDER EXTENDING PLAINTIFF'S TIME TO FILE SUMMARY JUDGEMENT MOTION

ALLISON CLAIRE, Magistrate Judge.

IT IS HEREBY STIPULATED by and between the parties, through their attorneys, that Plaintiff's time to file her summary judgment is hereby extended from December 12, 2012, to January 18, 2012. Plaintiff's counsel received the record in the form of an encrypted disk from Ms. Knox's former counsel. She forwarded the disc to the local U.S. Attorney's office on December 3, 2012, for decrypting and was informed today that a newly formatted disc would be mailed out this week. Therefore, plaintiff's counsel needs an additional extension within which to file Ms. Knox's summary judgment motion. See, Declaration set forth below.

DECLARATION

I, Bess M. Brewer, am counsel for plaintiff in the above referenced case which originated out of the State of Washington.

2. I substituted in as counsel on the case October 11, 2012, and received the record in the form of a disc the second week of November.

3. When I attempted to open the disc on December 3, 2012, I realized a different encryption had been utilized and the disc could not be opened. That same day, I contacted Karen Clark with the Attorney General's office who indicated she would obtain a new disc and get it to me ASAP.

5. On December 10, 2012, I recontacted Karen Clark regarding the status of the disc and was informed that she had not been able to open the disc and had forwarded it to ODAR. She promised to contact ODAR for an update and just informed me that ODAR had promised that the reformatted disc would be mailed to her office this week. She would then forward the disc to me.

6. Given the fact that I do not have the record combined with the upcoming holidays, I require an additional extension until January 18, 2012, within which to complete Ms. Knox's summary judgment motion.

ORDER

APPROVED AND SO ORDERED.