Martinez v. Commissioner of Social Security

Filing 17

STIPULATION and ORDER signed by Magistrate Judge Craig M. Kellison on 5/3/2017 Plaintiff's Summary Judgment is due by 5/15/2017. (Washington, S)

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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: 2:16-cv-00101-CMK

JOEL HERNANDEZ MARTINEZ,
Plaintiff,

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v.

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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, the Parties require additional time to determine whether

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supplementation of the administrative record by defendant is required including

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additional time for plaintiff to draft a summary judgment motion; and

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WHEREAS, an additional extension of 30 days is appropriate to file Plaintiff’s

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motion for his summary judgment brief until May 15, 2017 is required, and any reply by

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Defendant will be due 30 days thereafter, and is not requested for an improper purpose.

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See, FRCP 11; Unioil, Inc. v. E.F. Hutton & Co., 809 F.2d 548, 558 (9th Cir.1986).

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

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

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date for the filing of the brief of the motion for summary is May 15, 2017. This is the

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parties’ first request for additional time.

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Stipulation and Order

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SO STIPULATED AND AGREED:

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For Plaintiff:
WEEMS LAW OFFICES

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For Defendant:
PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel,
Region IX
Social Security Administration

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

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

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SO ORDERED:
DATED: May 3, 2017

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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
I declare under penalty of perjury under the laws of the United States of America

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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