(SS) Webber v. Commissioner of Social Security

Opinion

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 rcweems@weemslawoffices.com

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, STIPULATION AND ORDER FOR v. EXTENSION OF TIME Commissioner of Social Security, [Fed.R.Civ.P. 6] Defendant WHEREAS, Plaintiff’s Counsel of Record, Robert C. Weems, requires a third extension of time to continue revision to plaintiff’s draft motion to further develop arguments concerning, , changes to the regulations applicable to plainitff’s benefits application between her first and second applications; map dates when records were received relative to those applications; and refine arguments concerning the identification of impairments and weighing of opinion and other evidence in order to fully present plaintiff’s case; WHEREAS, Defendant’s Counsel of Record does not believe that the addition delay to permit Mr. Weems to finalize Plaintiff’s motion will prejudice the Commissioner; and, 1 WHEREAS, Mr. Weems anticipates he can finalize Plaintiff's motion within a further twenty-one (21) days from the date upon which plainitffs motion was due under the prior extension of time 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; Unioil, 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 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’ □ motion for summary judgment is January 5, 2021. } SO STIPULATED AND AGREED: i For Plaintiff: For Defendant: WEEMS LAW OFFICES MCGREGOR W. SCOTT United States Attomey DEBORAH LEE STACHEL Regional Chief Counsel, Region □□ Social Security Administration ELLINOR RAVENEL CODOR Special Assistant United States Attorney /s/Robert C. Weems By: /s/ Ellinor R. Codor Robert C. Weems, Ellinor R. Codor Attorney for Plaintiff Special Assistant United States Attorney and Attorney for the Defendant (per e-mail authorization) SO ORDERED: Dated: December 22, 2020 SSS. —_— << UNITED STATES MAGISTRATE JUDGE Stipulation and Order