Opinion
Robert C. Weems, WEEMS LAW OFFICES, Attorney for Plaintiff.
BENJAMIN B. WAGNER, United States Attorney DEBORAH LEE STACHEL Acting Regional Chief Counsel, Region IX Social Security Administration.
Heather M. Moss Special Assistant United States Attorney and Attorney for the Defendant, for Defendant.
STIPULATION AND ORDER FOR EXTENSION OF TIME [Fed.R.Civ.P. 6]
CRAIG M. KELLISON, Magistrate Judge.
WHEREAS, Counsel of Record Robert C. Weems requires additional time to draft a reply to Defendant's cross summary judgment motion;
WHEREAS, the need for more time is the result of Counsel of Record Robert C. Weems due to unanticipated demands of the filing of an indictment in the matter of People of the State of CA v. Ho in Tulare County; and
WHEREAS, an additional extension of 30 days is appropriate to file Plaintiff's motion for summary judgment until October 29, 2015 is required due to limited support staff familiar with the case, and is not requested for an improper purpose. See, FRCP 11; Unioil, Inc. v. E.F. Hutton & Co., 809 F.2d 548, 558 (9th Cir.1986).
NOW, WHEREFORE, the Parties, subject to the Court's approval, stipulate to an extension of all deadlines in this action. The revised due date for the filing of the motion for summary judgment is October 29, 2015. This is Plaintiff's first request for additional time.
SO STIPULATED AND AGREED:
SO ORDERED:
DECLARATION OF CONCURRENCE OF SIGNATURE GENERAL ORDER 45, X
I, Robert C. Weems, hereby declare and attest that concurrence in the filing of the document has been obtained from each of the other signatories, or from the single signatory (in the case, e.g., of a declaration) whose signature is indicated by the notation "/s/ [name of signatory]."
The filer shall maintain records to support this concurrence for subsequent production for the Court if so ordered or for inspection upon request by a party until one year after final resolution of the action (including appeal, if any) unless filer has attached a scanned image of the signature page (s) of the document being electronically filed in lieu in lieu of maintaining the paper record for subsequent production if required.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.