Reynolds v. Commissioner of Social Security
Filing
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STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 10/30/17, ORDERING that Plaintiff's reply to Defendant's cross-motion for summary judgment is EXTENDED to 12/14/2017. (Kastilahn, A)
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Robert C Weems (CA SBN 148156)
WEEMS LAW OFFICES
769 Center Blvd., PMB 38
Fairfax, CA 94930
Ph: 415.881.7653
Fx: 866.610.1430
rcweems@weemslawoffices.com
Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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JACKIE ANTHONY REYNOLDS,
Plaintiff,
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v.
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Case 2:16-cv-01652-EFB
STIPULATION AND PROPOSED ORDER
FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT
NANCY A. BERRYHILL, Acting
Commissioner of Social Security,
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Defendant.1
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IT IS HEREBY STIPULATED by and between the parties that Defendant shall have an
extension of 45 days to December 14, 2017, to file Plaintiff’s reply to Defendant’s cross motion for
summary judgment. This is Plaintiff’s third request for an extension of time, the first extension for
filing the motion for summary judgment being through June 16, 2017, and the second request for
filing a reply to Defendant’s cross motion for summary judgment through October 20, 2017. Plaintiff
did not recognize until now that Defendant had lodged a supplement to the administrative.
Plaintiff requires the additional time due to dealing with supplemental administrative record ,
Defendant’s reliance on the supplemental record, and unusual workload demands impacting the
ability to meet the current filing deadline in addition to having had to address unexpected, timeconsuming matters. Mr. Weems is a sole practitioner unable to reassign any of his cases as I am a
sole practitioner which resulted in the inadvertent oversight of the filing of the supplemental
administrative record at the same time of the filing of the cross motion for summary judgment.
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Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d)
of the Federal Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Acting
Commissioner Carolyn W. Colvin as the Defendant in this suit. No further action needs to be taken
to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42
U.S.C. § 405(g).
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STIPULATION TO EXTEND TIME TO REPLY TO CROSS MOTION
Case No. 2:16-cv-01652-EFB
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This request is made in good faith with no intention to unduly delay the proceedings.
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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.
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SO STIPULATED AND AGREED:
Dated: October 30, 2017
WEEMS LAW OFFICES
/s/ Robert C. Weems
Robert C. Weems,
Attorney for Plaintiff
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Dated: October 30, 2017
PHILLIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
MARCELO N. ILLARMO
Special Assistant United States Attorney
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/s/ Marcelo N. Illarmo
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Marcelo N. Illarmo
Special Assistant United States Attorney and
Attorney for Defendant (per e-mail
authorization)
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SO ORDERED.
DATED: October 30, 2017.
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STIPULATION TO EXTEND TIME TO REPLY TO CROSS MOTION
Case No. 2:16-cv-01652-EFB
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