Todd v. Astrue

Filing 31

STIPULATION AND ORDER FOR EXTENSION OF TIME. Signed by Judge ARMSTORNG on 12/26/12. (lrc, COURT STAFF) (Filed on 1/2/2013)

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Robert C Weems (CA SBN 148156)
Margaret M. Weems (CA SBN 164030)
WEEMS LAW OFFICES
769 Center Blvd., PMB 38
Fairfax, CA 94930
Ph: 415.881.7653
Fx: 866.610.1430

[e-mail]
Attorneys for Plaintiff
Jami B. Todd

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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Plaintiff,

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Case No: 4:10-cv-01381-SBA

JAMI B. TODD,

STIPULATION AND ORDER FOR
EXTENSION OF TIME
[Fed.R.Civ.P. 6]

v.
MICHAEL J. ASTRUE, Commissioner
of Social Security,
Defendant

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WHEREAS, Counsel of Record for Plaintiff, Robert C. Weems, requires

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additional time to draft Plaintiff’s opposition to Defendant’s cross-motion for summary

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judgment; and

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WHEREAS, an additional extension is appropriate due to the analysis required for

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briefing is taking longer than anticipated diligent efforts and the impact of holidays, and

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the additional 30 days is required due to preplanned vacations of limited support staff

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familiar with the case, and is not requested for an improper purpose. See, FRCP 11;

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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 a Thirty (30) days extension of all deadlines in this action.

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This is this counsel’s 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:
MELINDA L. HAAG
United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel,
Region IX
Social Security Administration

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By: /s/ Shea Lita Bond
Special Assistant United States
Attorney and Attorney for the
Defendant (per e-mail)

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

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SO ORDERED:

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DATE:12/26/12
SAUNDRA BROWN ARMSTRONG
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
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