(SS) Webber 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 DELORES DIANN WEBBER, Case No: 2:20-cv-00849-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 motion for summary judgment, having had an 22 unanticipated matters to which he had to personally attend due to covid-19 and other 23 issues interfering on completing work on the motion; 24 WHEREAS, Defendant’s Counsel of Record does not believe that a brief delay to 25 permit Mr. Weems to finalize Plaintiff’s motion will prejudice the Commissioner and this 26 is Mr. Weems first time requesting an extension; and, 27 WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s motion 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. BF. 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 file her motion 5 || for summary judgment in this action. The revised due date for the filing of plaintiff's 6 || motion for summary judgment is November 22, 2020. 7 ||SO STIPULATED AND AGREED: 8 For Plaintiff: For Defendant: 9 || WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Attomey 10 DEBORAH LEE STACHEL Regional Chief Counsel, Region IX 11 Social Security Administration ELLINOR RAVENEL CODOR 12 Special Assistant United States 13 Attorney 14 /s/Robert C. Weems By: /s/ Ellinor Ravenel. Codor 15 || Robert C. Weems, Attorney for Ellinor Ravenel Codor 16 || Plaintiff Special Assistant United States 7 Attorney and Attorney for the Defendant (per e-mail authorization) 18 19 SO ORDERED: 20 21 ||Dated: October 30, 2020 SSS 22 — DENNIS M. COTA 23 UNITED STATES MAGISTRATE 24 JUDGE 25 26 27 28 Stipulation and Order