(SS) Webber v. Commissioner of Social Security ( 2020 )

Robert C. Weems (SBN 148156) 1 WEEMS LAW OFFICES 2 526 3rd St., Ste. A-2 San Rafael, CA 94901 3 Ph: (415) 881-7653 4 Fx: (866) 610-1430 rcweems@weemslawoffices.com 5 6 Attorney for Plaintiff 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 SACRAMENTO DIVISION 11 12 DELORES DIANN WEBBER, Case No: 2:20-cv-00849-DMC 13 Plaintiff, STIPULATION AND ORDER FOR 14 v. EXTENSION OF TIME 15 Commissioner of Social Security, [Fed.R.Civ.P. 6] 16 Defendant 17 WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires a third 18 extension of time to continue revision to plaintiff’s draft motion to further develop 19 arguments concerning, , changes to the regulations applicable to plainitff’s 20 benefits application between her first and second applications; map dates when records 21 were received relative to those applications; and refine arguments concerning the 22 identification of impairments and weighing of opinion and other evidence in order to 23 fully present plaintiff’s case; 24 WHEREAS, Defendant’s Counsel of Record does not believe that the addition 25 delay to permit Mr. Weems to finalize Plaintiff’s motion will prejudice the 26 Commissioner; and, 27 28 1 1 WHEREAS, Mr. Weems anticipates he can finalize Plaintiff's motion within a 2 || further twenty-one (21) days from the date upon which plainitffs motion was due under 3 || the prior extension of time and is not requesting this extension for an improper purpose 4 || but to meet his professional obligations to this Court and avoid prejudice to Plaintiff. 5 ||See, FRCP 11; Unioil, Inc. v. EF. Hutton & Co., 809 F.2d 548, 558 (9th Cir. 1986). 6 NOW, WHEREFORE, the Parties agree good cause exists for and, subject to the 7 || Court’s approval, stipulate to a 21-day extension of time for Plaintiff to file her motion 8 || for summary judgment in this action. The revised due date for the filing of plaintiff’ □ 9 || motion for summary judgment is January 5, 2021. 10 |} SO STIPULATED AND AGREED: i For Plaintiff: For Defendant: 12 || WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Attomey 13 DEBORAH LEE STACHEL Regional Chief Counsel, Region □□ 14 Social Security Administration ELLINOR RAVENEL CODOR 15 Special Assistant United States 16 Attorney 7 /s/Robert C. Weems By: /s/ Ellinor R. Codor 18 || Robert C. Weems, Ellinor R. Codor 19 || Attorney for Plaintiff Special Assistant United States Attorney and Attorney for the Defendant (per e-mail authorization) 21 SO ORDERED: 22 23 || Dated: December 22, 2020 SSS. 24 —_— << 25 DENNIS M. COTA 26 UNITED STATES MAGISTRATE JUDGE 27 28 Stipulation and Order