(SS) Webber v. Commissioner of Social Security

Robert C. Weems (SBN 148156) WEEMS LAW OFFICES 526 3rd St., Ste. A-2 San Rafael, CA 94901 Ph: (415) 881-7653 Fx: (866) 610-1430 [email protected] Attorney for Plaintiff

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION DELORES DIANN WEBBER, Case No: 2:20-cv-00849-DMC Plaintiff, 16 STIPULATION AND ORDER FOR v. EXTENSION OF TIME Commissioner of Social Security, [Fed.R.Civ.P. 6] Defendant 20 WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires a second extension of time to finalize plaintiff’s motion for summary judgment in order to continue revisions to the draft motion in order to further develop arguments related to an issue not previously identified during review of the administrative record and initial drafting, which issue may be dispositive; 25 WHEREAS, Defendant’s Counsel of Record does not believe that a brief delay to permit Mr. Weems to finalize Plaintiff’s motion will prejudice the Commissioner; and, 27 WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s motion within twenty-one (21) days and is not requesting this extension for an improper purpose but to || meet his professional obligations to this Court and avoid prejudice to Plaintiff. See, || FRCP 11; Unroil, Inc. 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 || Court’s approval, stipulate to a 21-day extension of time for Plaintiff to file her motion || for summary judgment in this action. The revised due date for the filing of plaintiff's || motion for summary judgment is December 15, 2020 ||SO STIPULATED AND AGREED: For Plaintiff: For Defendant: || WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Atlomey 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 R. Codor || Robert C. Weems, Ellinor R. Codor || Attorney for Plaintiff Special Assistant United States 7 Attorney and Attorney for the Defendant (per e-mail authorization) SO ORDERED: 21 Dated: November 25, 2020 SSS 22 ——— ee 23 DENNIS M. COTA 24 UNITED STATES MAGISTRATE JUDGE Stipulation and Order