(SS) Lee-Klein v. Commissioner of Social Security

E.D. California

(SS) Lee-Klein v. Commissioner of Social Security

District Court, E.D. California·Decided October 30, 2020·No. 2:19-cv-02335·Unknown

Opinion

Robert C. Weems (SBN 148156) WEEMS LAW OFFICES 769 Center Blvd., PMB 38 Fairfax, CA 94930 Ph: (415) 881-7653 Fx: (866) 610-1430 rcweems@weemslawoffices.com

Attorney for Plaintiff

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

CHRISTINA LEE-KLEIN, Case No: 2:19-cv-02335-DMC

Plaintiff, v. EXTENSION OF TIME Commissioner of Social Security, [Fed.R.Civ.P. 6] Defendant WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires an extension of time to finalize Plaintiff’s reply to Defendant’s cross-motion, having had matters to which he had to personally attend due to covid-19 and other issues interfering on completing work on the reply; WHEREAS, Defendant’s Counsel of Record does not believe that a delay to permit Mr. Weems to reply to Defendant’s cross-motion will prejudice the Commissioner and this is Mr. Weems first time requesting an extension; and, WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s reply in not more than twenty-eight (28) calendar days and is not requesting this extension for an improper 1 purpose but to meet his professional obligations to this Court. See, FRCP 11; □□□□□□□ Inc. v. EF. Hutton & Co., 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 a 28-day extension of time for Plaintiff to reply to Defendant’s cross-motion in this action. The revised due date for the filing of plaintiff's reply is November 23, 2020. SO STIPULATED AND AGREED: For Plaintiff: For Defendant: WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Atlomey DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration TIMOTHY R. BOLIN Special Assistant United States Attorney /s/Robert C. Weems By: /s/ Timothy R. Bolin Robert C. Weems, Attorney for Timothy R. Bolin Plaintiff Special Assistant United States Attorney and Attorney for the Defendant (per e-mail authorization) IT IS SO ORDERED: Dated: October 30, 2020 _ ES UNITED STATES MAGISTRATE Stipulation and Order

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Robert C. Weems (SBN 148156) WEEMS LAW OFFICES 769 Center Blvd., PMB 38 Fairfax, CA 94930 Ph: (415) 881-7653 Fx: (866) 610-1430 rcweems@weemslawoffices.com

Attorney for Plaintiff

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

CHRISTINA LEE-KLEIN, Case No: 2:19-cv-02335-DMC

Plaintiff, v. EXTENSION OF TIME Commissioner of Social Security, [Fed.R.Civ.P. 6] Defendant WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires an extension of time to finalize Plaintiff’s reply to Defendant’s cross-motion, having had matters to which he had to personally attend due to covid-19 and other issues interfering on completing work on the reply; WHEREAS, Defendant’s Counsel of Record does not believe that a delay to permit Mr. Weems to reply to Defendant’s cross-motion will prejudice the Commissioner and this is Mr. Weems first time requesting an extension; and, WHEREAS, Mr. Weems anticipates he can finalize Plaintiff’s reply in not more than twenty-eight (28) calendar days and is not requesting this extension for an improper 1 purpose but to meet his professional obligations to this Court. See, FRCP 11; □□□□□□□ Inc. v. EF. Hutton & Co., 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 a 28-day extension of time for Plaintiff to reply to Defendant’s cross-motion in this action. The revised due date for the filing of plaintiff's reply is November 23, 2020. SO STIPULATED AND AGREED: For Plaintiff: For Defendant: WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Atlomey DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration TIMOTHY R. BOLIN Special Assistant United States Attorney /s/Robert C. Weems By: /s/ Timothy R. Bolin Robert C. Weems, Attorney for Timothy R. Bolin Plaintiff Special Assistant United States Attorney and Attorney for the Defendant (per e-mail authorization) IT IS SO ORDERED: Dated: October 30, 2020 _ ES UNITED STATES MAGISTRATE Stipulation and Order

(SS) Lee-Klein v. Commissioner of Social Security, (E.D. Cal. 2020).

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