Price v. Berryhill

Filing 20

ORDER Granting 19 Stipulation for Extension of Time re 16 Motion to Remand to Agency (Second Request). Responses due by 9/15/2017. Signed by Magistrate Judge Cam Ferenbach on 8/29/17. (Copies have been distributed pursuant to the NEF - MR)

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Cyrus Safa
Attorney at Law: 13241
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

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Gerald M. Welt
Attorney at Law: 1575
703 S. Eight St.
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]

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Attorneys for Plaintiff

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STEVEN W. MYHRE (NSBN 9635)
Acting United States Attorney
District of Nevada
TINA L. NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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TINISHA PRICE
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Plaintiff,
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v.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:17-cv-00755-JCM-VCF
JOINT STIPULATION FOR EXTENSION OF
TIME TO FILE DEFENDANT’S NOTICE OF
VOLUNTARY REMAND OF THE CASE OR
CROSS-MOTION TO AFFIRM
(Second Request)

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that
the time for responding to Plaintiff’s Motion for Summary Judgment be extended for approximately
two weeks from August 31, 2017 to September 15, 2017. This is Defendant’s second request for

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extension. Good cause exists to grant Defendant’s request for extension. Additional time is required
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as Counsel for Defendant (Counsel) has over 50+ active matters, of which two dispositive motions per

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week until the early October. Counsel has been on intermittent medical leave due to her chronic

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migraines and daily recurrent headaches. As a result of unanticipated medical leave, Counsel became

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behind on her caseload. As such, Counsel respectfully requests additional time in order to address the

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issues raised in Plaintiff’s Motion. Defendant makes this request in good faith with no intention to
unduly delay the proceedings. Plaintiff has no objection to the requested relief.

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The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Date:

August 29, 2017
By:

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Date:

August 29, 2017

/s/ Cyrus Safa
CYRUS SAFA
*by email authorization on 8/29/17
Attorney for Plaintiff
STEVEN W. MYHRE
Acting United States Attorney

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By:/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney

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IT IS SO ORDERED.

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DATE:

August 29, 2017
THE HONORABLE CAM FERENBACH
United States Magistrate Judge

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CERTIFICATE OF SERVICE

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I, TINA L. NAICKER, certify that the following individual was served with a copy of the

3 JOINT STIPULATION FOR EXTENSION OF TIME TO FILE DEFENDANT’S NOTICE OF
4 VOLUNTARY REMAND OF THE CASE OR CROSS-MOTION TO AFFIRM
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on the date and via the method of service identified below:

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CM/ECF:
Cyrus Safa
Attorney at Law: 13241
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]
Gerald M. Welt
Attorney at Law: 1575
703 S. Eight St.
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]

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Respectfully submitted this 29th day of August 2017,

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney

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