Baxter v. Colvin

Filing 24

STIPULATION AND ORDER FOR EXTENSION OF TIME granting 23 STIPULATION. Reply to 20 MOTION for Summary Judgment due by 10/28/2014. Signed by Judge William H. Orrick on 10/16/2014. (jmdS, COURT STAFF) (Filed on 10/16/2014)

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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 NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Case No: 3:14-cv-01306-WHO

JAIME AMANDA BAXTER,
Plaintiff,

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v.

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CAROLYN W. COLVIN, Acting

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

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a reply to Defendant’s cross motion for summary judgment motion; and
WHEREAS, an optional reply is due on September 13, 2014 , and the analysis

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required for briefing is taking longer than anticipated despite diligent efforts by the

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parties, an additional 14 days is required due to limited support staff familiar with the

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

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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 a fourteen (14) days extension of all deadlines in this

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action. The revised due date for the filing of the reply to Defendant’s cross motion for

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Stipulation and Order

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summary judgment is October 28, 2014. This is the parties’ second request for additional

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time.

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SO STIPULATED AND AGREED:
For Plaintiff:
WEEMS LAW OFFICES

For Defendant:
MELINDA L. HAAG
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel,
Region IX
Social Security Administration

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

By: /s/ Jean Marie Turk
Special Assistant United States
Attorney and Attorney for the
Defendant (per e-mail)

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SO ORDERED:
DATE: October 16, 2014
WILLIAM H. ORRICK
JUDGE OF THE UNITED STATES
DISTRICT COURT

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Stipulation and Order

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DECLARATION OF CONCURRENCE OF SIGNATURE

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GENERAL ORDER 45, X

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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

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