Hillen v. Commissioner of Social Security

Filing 20

ORDER Granting 19 Stipulation to Extend Time to File Motion for Reversal. See Order for deadlines. Signed by Magistrate Judge Cam Ferenbach on 3/8/17. (Copies have been distributed pursuant to the NEF - ADR)

Download PDF
1 2 3 4 5 6 Cyrus Safa Attorney at Law: 282971 12631 East Imperial Highway, Suite C-115 Santa Fe Springs, CA 90670 Tel: (562)437-7006 Fax: (562)432-2935 E-Mail: rohlfing.office@rohlfinglaw.com Attorneys for Plaintiff CHADD M. HILLEN 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 12 CHADD M. HILLEN Plaintiff, 13 v. 14 NANCY A. BERRYHILL, Acting Commissioner of Social Security. 15 Defendant. 16 17 ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:16-cv-00913-JCM-VCF STIPULATION TO EXTEND TIME TO FILE MOTION FOR REVERSAL AND/OR REMAND 18 Plaintiff Chadd M. Hillen and Defendant Carolyn W. Colvin, Acting 19 20 21 22 23 24 25 26 27 28 Commissioner of Social Security, through their undersigned attorneys, stipulate, subject to this court’s approval, to extend the time to April 3, 2017 for Plaintiff to file Plaintiff’s Motion for Reversal and/or Remand; and that Defendant shall have until May 3, 2017, to file her opposition, if any is forthcoming. Any reply by plaintiff will be due May 23, 2017. /// /// -1- 1 As the Court is aware, after a 5 year battle with terminal stage 4 cancer 2 Plaintiff’s Counsel’s Spouse of the associate, who this matter is assigned to, passed 3 away on September 30, 2016. The aftermath of this traumatic event on both 4 Counsel and his 9 year old son and 7 year old daughter was immeasurable. 5 Compounding the impact of this loss is the fact that Counsel’s spouse was a former 6 employee at Counsel’s Law Firm and her death was far reaching in its impact on 7 Counsel’s professional life as well. Due to the death, the subsequent holiday 8 period, and the need to find a permanent caregiver and the required time to 9 acclimate his children to that presence during his absence to meet his professional 10 obligations, Counsel requires the additional time to prepare and file her motion for 11 summary judgment. 12 Counsel for plaintiff does not anticipate this extraordinary request for more time to 13 become the rule and recognizes it is the extraordinary exception and sincerely 14 apologizes to the court for any inconvenience this may have had upon it or its staff. 15 16 17 /// /// /// /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 24 25 /// /// /// /// 26 27 28 -2- 1 DATE: March 8, 2017 Respectfully submitted, LAWRENCE D. ROHLFING 2 /s/ Cyrus Safa 3 BY: _______________________ Cyrus Safa Attorney for plaintiff Mr. Chadd M. Hillen 4 5 6 7 DATE: March 8, 2017 8 Daniel G. Bogden United States Attorney /s/ April A. Alongi 9 BY: ____________________________ April A. Alongi Special Assistant United States Attorney Attorneys for defendant Nancy A. Berryhill |*authorized by e-mail| 10 11 12 13 14 DATED: 3/8/17 15 IT IS SO ORDERED: 16 UNITED STATES MAGISTRATE JUDGE 17 18 19 20 21 22 23 24 25 26 27 28 -3- 1 CERTIFICATE OF SERVICE FOR CASE NUMBER 2:16-CV-00913-JCM-VCF 2 3 4 5 6 I hereby certify that I electronically filed the foregoing with the Clerk of the Court for this court by using the CM/ECF system on March 8, 2017. I certify that all participants in the case are registered CM/ECF users and that service will be accomplished by the CM/ECF system. 7 8 9 10 /s/ Cyrus Safa _______________________________ Cyrus Safa Attorneys for Plaintiff 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4-

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?