(SS) Ferraris v. Commissioner of Social Security ( 2021 )

1 Robert C. Weems (SBN 148156) WEEMS LAW OFFICES 2 526 Third Street, Ste. A-2 San Rafael, CA 94901 3 Ph: 415.881.7653 4 Fx: 866.610.1430 Email: rcweems@weemslawoffices.com 5 Attorney for Plaintiff, 6 MATTHEW JAMES FERRARIS 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 MATTHEW JAMES FERRARIS, Case 2:21-cv-00132-CKD 12 Plaintiff, STIPULATION AND ORDER FOR 13 v. EXTENSION OF TIME 14 COMMISSIONER OF SOCIAL SECURITY, 15 Defendant. 16 17 WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires an extension of time to finalize Plaintiff’s motion for summary judgment because, due to staff unavailability to develop 18 the facts for the draft, is not in fileable order; 19 WHEREAS, Defendant’s Counsel of Record does not believe that a delay to permit Mr. 20 Weems to file Plaintiff’s motion for summary judgment will prejudice the Commissioner and this is 21 Mr. Weems first time requesting an extension; and, 22 WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s motion for summary judgment 23 in not more than an additional thirty (30) calendar days and is not requesting this extension for an 24 improper purpose but to meet his professional obligations to this Court. See, FRCP 11; 25 , 809 F.2d 548, 558 (9th Cir. 1986). NOW, WHEREFORE, the Parties agree good cause exists for and, subject to the Court’s 26 approval, stipulate to an extension of time for Plaintiff to file Plaintiff’s motion for summary 27 judgment in this action. The revised due date for the filing of Plaintiff’s motion for summary 28 judgment is December 29, 2021. 1 . 2} SO STIPULATED AND AGREED, November 30, 2021: 3} For Plaintiff: For Defendant: 4) WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Attorney 5 DEBORAH LEE STACHEL Regional Chief Counsel, Region IX 6 Social Security Administration 7 LINDA H. GREEN Special Assistant U.S. Attorney g| _/s/Robert C. Weems By: /s/Linda H. Green Robert C. Weems, LINDA H. GREEN, 9} Attorney for Plaintiff Special Assistant United States Attorney 10 and Attorney for the Defendant (by direction) 11 12 IT IS SO ORDERED. 3 Dated: November 30, 2021 7) i ae 14 CLANK 7 fv. { A. Le (A 15 CAROLYN K. DELANEY ' UNITED STATES MAGISTRATE JUDGE 16 17 18 19 20 21 22 23 24 25 26 27 28