(SS) Ferraris v. Commissioner of Social Security

Robert C. Weems (SBN 148156) WEEMS LAW OFFICES Third Street, Ste. A-2 San Rafael, CA 94901 Ph: 415.881.7653 Fx: 866.610.1430 Email: [email protected] Attorney for Plaintiff, MATTHEW JAMES FERRARIS

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA MATTHEW JAMES FERRARIS, Case 2:21-cv-00132-CKD Plaintiff, STIPULATION AND ORDER FOR v. EXTENSION OF TIME COMMISSIONER OF SOCIAL SECURITY, Defendant.

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 the facts for the draft, is not in fileable order; WHEREAS, Defendant’s Counsel of Record does not believe that a delay to permit Mr. Weems to file Plaintiff’s motion for summary judgment will prejudice the Commissioner and this is Mr. Weems first time requesting an extension; and, WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s motion for summary judgment in not more than an additional thirty (30) calendar days and is not requesting this extension for an improper purpose but to meet his professional obligations to this Court. See, FRCP 11; , 809 F.2d 548, 558 (9th Cir. 1986).

NOW, WHEREFORE, the Parties agree good cause exists for and, subject to the Court’s approval, stipulate to an extension of time for Plaintiff to file Plaintiff’s motion for summary judgment in this action. The revised due date for the filing of Plaintiff’s motion for summary judgment is December 29, 2021. .

2} SO STIPULATED AND AGREED, November 30, 2021: 3} For Plaintiff: For Defendant: 4) WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration 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 and Attorney for the Defendant (by direction)

IT IS SO ORDERED.

Dated: November 30, 2021 7) i ae CLANK 7 fv. { A. Le (A CAROLYN K. DELANEY ' UNITED STATES MAGISTRATE JUDGE