Price v. Berryhill

Filing 22

ORDER Granting 21 Stipulation for Extension of Time re 16 Motion to Remand to Agency (Third Request). Responses due by 9/22/2017. Signed by Magistrate Judge Cam Ferenbach on 9/15/17. (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
(Third 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 one week from
September 15, 2017 to September 22, 2017. This is Defendant’s third request for extension. Good

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cause exists to grant Defendant’s request for extension. Counsel continues to have deabilitating
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migraines and daily headaches and is on intermittent medical leave. As a result of unanticipated

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medical leave, Counsel respectfully requests additional time in order to address the issues raised in

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Plaintiff’s Motion. Defendant makes this request in good faith with no intention to unduly delay the

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proceedings. Plaintiff has no objection to the requested relief. The parties further stipulate that the

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Court’s Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Date:

September 14, 2017
By:

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Date:

September 14, 2017

/s/ Cyrus Safa
CYRUS SAFA
*by email authorization on 9/14/17
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:

9-15-2017
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 14th day of September 2017,

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

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