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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1 2 3 4 5 6 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 Attorneys for Plaintiff Jami B. Todd 7 UNITED STATES DISTRICT COURT 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 10 Plaintiff, 11 12 13 14 15 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 16 WHEREAS, Counsel of Record for Plaintiff, Robert C. Weems, requires 17 additional time to draft Plaintiff’s opposition to Defendant’s cross-motion for summary 18 judgment; and 19 WHEREAS, an additional extension is appropriate due to the analysis required for 20 briefing is taking longer than anticipated diligent efforts and the impact of holidays, and 21 the additional 30 days is required due to preplanned vacations of limited support staff 22 familiar with the case, and is not requested for an improper purpose. See, FRCP 11; 23 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 a Thirty (30) days extension of all deadlines in this action. 26 This is this counsel’s first request for additional time. 27 28 1 Stipulation and Order 1 SO STIPULATED AND AGREED: 2 For Plaintiff: WEEMS LAW OFFICES 3 For Defendant: MELINDA L. HAAG United States Attorney DONNA L. CALVERT Acting Regional Chief Counsel, Region IX Social Security Administration 4 5 6 7 8 9 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 10 11 12 SO ORDERED: 13 DATE:12/26/12 SAUNDRA BROWN ARMSTRONG JUDGE OF THE UNITED STATES DISTRICT COURT 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 7 8 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 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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