Moon v. Commisioner of Social Security

Filing 15

STIPULATION AND ORDER signed by Magistrate Judge Allison Claire on 2/22/2016 ORDERING the plaintiff to file a Motion for Summary Judgment by 3/10/2016. (Michel, G.)

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Robert C. Weems (SBN 148156)
WEEMS LAW OFFICES
769 Center Blvd., PMB 38
Fairfax, CA 94930
Ph: [phone]
Fx: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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Case No: 2:14-cv-00861-AC

ANDY ALLAN MOON,
Plaintiff,

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v.

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CAROLYN W. COLVIN, Acting

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STIPULATION AND ORDER FOR
EXTENSION OF TIME
[Fed.R.Civ.P. 6]

Commissioner of Social Security,

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Defendant

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WHEREAS, Counsel of Record Robert C. Weems requires additional time to draft

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the motion for summary judgment motion;
WHEREAS, the need for more time is the result of Counsel of Record Robert C.
Weems due to unanticipated demands of his criminal court demands; and

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WHEREAS, an additional extension of 20 days is appropriate to file Plaintiff’s

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motion for summary judgment until March 10, 2016 is required due to limited support

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staff familiar with the case, and is not requested for an improper purpose. See, FRCP 11;

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Unioil, Inc. v. E.F. Hutton & Co., 809 F.2d 548, 558 (9th Cir.1986).

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NOW, WHEREFORE, the Parties, subject to the Court’s approval, stipulate to an

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extension of all deadlines in this action. The revised due date for the filing of the motion

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Stipulation and Order

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for summary judgment is March 10, 2016. This is Plaintiff’s first request for additional

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time.

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SO STIPULATED AND AGREED:
For Plaintiff:
WEEMS LAW OFFICES

For Defendant:
BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel,
Region IX
Social Security Administration

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/s/Robert C. Weems
Robert C. Weems, Attorney for
Plaintiff

By: /s/ Richard Rodriguez
Special Assistant United States
Attorney and Attorney for the
Defendant (per e-mail)

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SO ORDERED:
DATE: February 22, 2016

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ALLISON CLAIRE
MAGISTRATE JUDGE OF THE
UNITED STATES DISTRICT COURT

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Stipulation and Order

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DECLARATION OF CONCURRENCE OF SIGNATURE

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GENERAL ORDER 45, X
I, Robert C. Weems, hereby declare and attest that concurrence in the filing of the

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document has been obtained from each of the other signatories, or from the single

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signatory (in the case, e.g., of a declaration) whose signature is indicated by the notation

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“ /s/ [name of signatory].”1

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I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
/s/ Robert C. Weems
Robert C. Weems

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The filer shall maintain records to support this concurrence for subsequent production
for the Court if so ordered or for inspection upon request by a party until one year after
final resolution of the action (including appeal, if any) unless filer has attached a scanned
image of the signature page(s) of the document being electronically filed in lieu of
maintaining the paper record for subsequent production if required.
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Stipulation and Order