Kingsley v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 10/15/15 ORDERING that the deadline for filing plaintiff's Motion for Summary Judgment is EXTENDED to 11/09/15.(Benson, A)

1
2
3
4
5
6

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

7
8

UNITED STATES DISTRICT COURT

9

FOR THE EASTERN DISTRICT OF CALIFORNIA

10

SACRAMENTO DIVISION

11
12

No. 2:14-cv-01157-DAD

AMBER RAE KINGSLEY,
Plaintiff,

13
14

v.

15

CAROLYN W. COLVIN, Acting

16

STIPULATION AND ORDER FOR
EXTENSION OF TIME

Commissioner of Social Security,

17

Defendant

18

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

19
20

a summary judgment motion; and
WHEREAS, an additional extension of 30 days is appropriate to file Plaintiff’s

21

motion for summary judgment until November 9, 2015 is required due to limited support

22

staff familiar with the case and the exceedingly large administrative record of over 1400

23

pages, and is not requested for an improper purpose. See, FRCP 11; Unioil, Inc. v. E.F.

24

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

25

NOW, WHEREFORE, the Parties agree good cause exists for and, subject to the

26

Court’s approval, stipulate to an extension of all deadlines in this action. The revised due

27

date for the filing of the motion for summary judgment is November 9, 2015. This is the

28

parties’ first request for additional time.

1

1
2
3
4
5

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

6
7
8
9
10
11

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

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

12
13
14

ORDER

15
16
17
18

Pursuant to the parties’ stipulation, IT IS SO ORDERED.
Dated: October 15, 2015

19
20
21
22
23
24

Ddad1\orders.soc sec
kingsley1157.stip.eot.ord.docx

25
26
27
28
2