Smart v. Commissioner of Social Security

Filing 20

STIPULATION AND ORDER FOR EXTENSION OF TIME signed by Magistrate Judge Craig M. Kellison on 6/13/17. The revised due date for the filing of the reply is 6/14/2017. (Mena-Sanchez, L)

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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-01145-CMK EDWARD JAMES SMART, Plaintiff, 13 14 v. 15 NANCY A. BERRYHILL, Acting 16 STIPULATION AND ORDER FOR EXTENSION OF TIME [Fed.R.Civ.P. 6] Commissioner of Social Security, 17 Defendant 18 WHEREAS, Counsel of Record Robert C. Weems requires additional time to draft 19 20 21 22 the a reply to Defendant’s cross-motion for summary judgment; 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 WHEREAS, an additional extension of 20 days is appropriate to file Plaintiff’s 23 reply until June 14, 2017 is required due to limited support staff familiar with the case, 24 and is not requested for an improper purpose. See, FRCP 11; Unioil, Inc. v. E.F. Hutton 25 & Co., 809 F.2d 548, 558 (9th Cir.1986). 26 27 NOW, WHEREFORE, the Parties, subject to the Court’s approval, stipulate to an extension of all deadlines in this action. The revised due date for the filing of the reply is 28 1 Stipulation and Order 1 June 14, 2017. While this is Plaintiff’s second request for additional time, Defendant has 2 no objection to this request. 3 4 5 6 7 SO STIPULATED AND AGREED: For Plaintiff: WEEMS LAW OFFICES For Defendant: BENJAMIN B. WAGNER United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 8 9 10 11 12 13 /s/Robert C. Weems Robert C. Weems, Attorney for Plaintiff By: /s/ Marcello Illarmo Special Assistant United States Attorney and Attorney for the Defendant (per e-mail) 14 15 16 17 18 SO ORDERED: Dated: June 13, 2017 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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