Filed: Aug. 08, 2019
Latest Update: Aug. 08, 2019
Summary: STIPULATION AND ORDER FOR MODIFICATION OF SCHEDULING ORDER [ECF No. 5] [Fed.R.Civ.P. 6] DENNIS M. COTA , Magistrate Judge . The parties hereby stipulate and agree this date of August 5, 2019, subject to the Court's approval and order, that there is good cause to extend time and to modify the scheduling order, ECF No. 5, and that Plaintiff's time to file a motion for summary judgment and/or remand be extended 31 days from August 5, 2019 to September 5, 2019. Defendant shall respond to Plaint
Summary: STIPULATION AND ORDER FOR MODIFICATION OF SCHEDULING ORDER [ECF No. 5] [Fed.R.Civ.P. 6] DENNIS M. COTA , Magistrate Judge . The parties hereby stipulate and agree this date of August 5, 2019, subject to the Court's approval and order, that there is good cause to extend time and to modify the scheduling order, ECF No. 5, and that Plaintiff's time to file a motion for summary judgment and/or remand be extended 31 days from August 5, 2019 to September 5, 2019. Defendant shall respond to Plainti..
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STIPULATION AND ORDER FOR MODIFICATION OF SCHEDULING ORDER [ECF No. 5] [Fed.R.Civ.P. 6]
DENNIS M. COTA, Magistrate Judge.
The parties hereby stipulate and agree this date of August 5, 2019, subject to the Court's approval and order, that there is good cause to extend time and to modify the scheduling order, ECF No. 5, and that Plaintiff's time to file a motion for summary judgment and/or remand be extended 31 days from August 5, 2019 to September 5, 2019. Defendant shall respond to Plaintiff's motion for summary judgment and/or remand on or before October 7, 2019, with all other deadlines likewise extended.
This is Plaintiff's first extension of time. The good cause supporting this stipulation includes, but is not limited to, that plaintiff's counsel cannot with diligence meet professional standards in the development and presentation of issues without prejudice to Plaintiff within the non-case-specific deadlines of the scheduling order.
This modification of the scheduling order is requested in good faith, with no intent to prolong proceedings unduly.
SO STIPULATED AND AGREED:
For Plaintiff: For Defendant:
WEEMS LAW OFFICES McGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
SHARON LAHEY
Assistant Regional Counsel
Social Security Administration
/s/ Robert C. Weems By: /s/ Sharon Lahey
Robert C. Weems, Attorney for Sharon Lahey
Plaintiff Assistant Regional Counsel
Attorney for the Defendant (per e-mail
authorization)
SO ORDERED, NUNC PRO TUNC TO AUGUST 5, 2019:
DECLARATION OF CONCURRENCE OF SIGNATURE GENERAL ORDER 131, 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]."1
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
/s/ Robert C. Weems
Robert C. Weems
