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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1 2 3 4 5 6 Robert C. Weems (SBN 148156) WEEMS LAW OFFICES 769 Center Blvd., PMB 38 Fairfax, CA 94930 Ph: (415) 881-7653 Fx: (866) 610-1430 Attorney for Plaintiff 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 SACRAMENTO DIVISION 11 12 Case No: 2:16-cv-00101-CMK JOEL HERNANDEZ MARTINEZ, Plaintiff, 13 14 v. 15 STIPULATION AND ORDER FOR EXTENSION OF TIME [Fed.R.Civ.P. 6] Commissioner of Social Security, 16 Defendant 17 WHEREAS, the Parties require additional time to determine whether 18 supplementation of the administrative record by defendant is required including 19 additional time for plaintiff to draft a summary judgment motion; and 20 WHEREAS, an additional extension of 30 days is appropriate to file Plaintiff’s 21 motion for his summary judgment brief until May 15, 2017 is required, and any reply by 22 Defendant will be due 30 days thereafter, and is not requested for an improper purpose. 23 See, FRCP 11; Unioil, Inc. v. E.F. Hutton & Co., 809 F.2d 548, 558 (9th Cir.1986). 24 NOW, WHEREFORE, the Parties agree good cause exists for and, subject to the 25 Court’s approval, stipulate to an extension of all deadlines in this action. The revised due 26 date for the filing of the brief of the motion for summary is May 15, 2017. This is the 27 parties’ first request for additional time. 28 1 Stipulation and Order 1 SO STIPULATED AND AGREED: 2 For Plaintiff: WEEMS LAW OFFICES 3 For Defendant: PHILLIP A. TALBERT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 4 5 6 7 8 9 /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) 10 11 12 13 SO ORDERED: DATED: May 3, 2017 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Stipulation and Order 1 DECLARATION OF CONCURRENCE OF SIGNATURE 2 GENERAL ORDER 45, X I, Robert C. Weems, hereby declare and attest that concurrence in the filing of the 3 4 document has been obtained from each of the other signatories, or from the single 5 signatory (in the case, e.g., of a declaration) whose signature is indicated by the notation 6 “ /s/ [name of signatory].” 1 I declare under penalty of perjury under the laws of the United States of America 7 8 that the foregoing is true and correct. /s/ Robert C. Weems Robert C. Weems 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 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. 3 Stipulation and Order

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