(SS) Lee-Klein v. Commissioner of Social Security ( 2020 )

Robert C. Weems (SBN 148156) 1 WEEMS LAW OFFICES 2 769 Center Blvd., PMB 38 Fairfax, CA 94930 3 Ph: (415) 881-7653 4 Fx: (866) 610-1430 rcweems@weemslawoffices.com 5 6 Attorney for Plaintiff 7 8 9 10 UNITED STATES DISTRICT COURT 11 FOR THE EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO DIVISION 13 14 CHRISTINA LEE-KLEIN, Case No: 2:19-cv-02335-DMC 15 Plaintiff, 16 STIPULATION AND ORDER FOR v. EXTENSION OF TIME 17 Commissioner of Social Security, [Fed.R.Civ.P. 6] 18 Defendant 19 20 WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires an 21 extension of time to finalize Plaintiff’s reply to Defendant’s cross-motion, having had 22 matters to which he had to personally attend due to covid-19 and other issues interfering 23 on completing work on the reply; 24 WHEREAS, Defendant’s Counsel of Record does not believe that a delay to 25 permit Mr. Weems to reply to Defendant’s cross-motion will prejudice the Commissioner 26 and this is Mr. Weems first time requesting an extension; and, 27 WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s reply in not more 28 than twenty-eight (28) calendar days and is not requesting this extension for an improper 1 1 || purpose but to meet his professional obligations to this Court. See, FRCP 11; □□□□□□□ Inc. 2 || v. EF. Hutton & Co., 809 F.2d 548, 558 (9th Cir. 1986). 3 NOW, WHEREFORE, the Parties agree good cause exists for and, subject to the 4 || Court’s approval, stipulate to a 28-day extension of time for Plaintiff to reply to 5 || Defendant’s cross-motion in this action. The revised due date for the filing of plaintiff's 6 || reply is November 23, 2020. 7 ||SO STIPULATED AND AGREED: 8 For Plaintiff: For Defendant: 9 || WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Atlomey 10 DEBORAH LEE STACHEL Regional Chief Counsel, Region IX 11 Social Security Administration TIMOTHY R. BOLIN 12 Special Assistant United States 13 Attorney 14 /s/Robert C. Weems By: /s/ Timothy R. Bolin 15 || Robert C. Weems, Attorney for Timothy R. Bolin 16 || Plaintiff Special Assistant United States 7 Attorney and Attorney for the Defendant (per e-mail authorization) 18 19 IT IS SO ORDERED: 20 21 Dated: October 30, 2020 22 _ ES 23 DENNIS M. COTA UNITED STATES MAGISTRATE 24 JUDGE 25 26 27 28 Stipulation and Order