Turpin v. Commissioner of Social Security

Filing 16

ORDER Granting 15 Stipulation for Extension of Time. Motions due by 5/11/2017. Responses due by 6/12/2017. Replies due by 7/3/2017. Signed by Judge Richard F. Boulware, II on 3/9/17. (Copies have been distributed pursuant to the NEF - MR)

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Cyrus Safa

Attorney at Law: 282971
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
JAMES A. TURPIN

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JAMES A. TURPIN
Plaintiff,

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v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security.

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Defendant.

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Case No.: 2:16-cv-01695-RFB-PAL
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR REVERSAL
AND/OR REMAND
(FIRST REQUEST)

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Plaintiff James A. Turpin and Defendant Carolyn W. Colvin, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,
subject to this court’s approval, to extend the time to May 11, 2017 for Plaintiff to
file Plaintiff’s Motion for Reversal and/or Remand; and that Defendant shall have
until June 12, 2017, to file her opposition, if any is forthcoming. Any reply by
plaintiff will be due July 3, 2017.
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As the Court is aware, after a 5 year battle with terminal stage 4 cancer

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Plaintiff’s Counsel’s Spouse of the associate, who this matter is assigned to, passed

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away on September 30, 2016. The aftermath of this traumatic event on both

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Counsel and his 9 year old son and 7 year old daughter was immeasurable.

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Compounding the impact of this loss is the fact that Counsel’s spouse was a former

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employee at Counsel’s Law Firm and her death was far reaching in its impact on

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Counsel’s professional life as well. Due to the death, the subsequent holiday

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period, and the need to find a permanent caregiver and the required time to

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acclimate his children to that presence during his absence to meet his professional

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obligations, Counsel requires the additional time to prepare and file her motion for

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summary judgment.

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Counsel for plaintiff does not anticipate this extraordinary request for more

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time to become the rule and recognizes it is the extraordinary exception and

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sincerely apologizes to the court for any inconvenience this may have had upon it

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or its staff.

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DATE: March 8, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Mr. James A. Turpin

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DATE: March 8, 2017

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Daniel G. Bogden
United States Attorney

/s/ Jeffrey T. Chen

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BY: ____________________________
Jeffrey T. Chen
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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DATED:
IT IS SO ORDERED:
UNITED STATES MAGISTRATE JUDGE

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DATED this 9th day of March, 2017.

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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:16-CV-01695-RFB-PAL
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.
/s/ Cyrus Safa
_______________________________
Cyrus Safa
Attorneys for Plaintiff

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