Moore v. Commissioner of Social Security

Filing 16

ORDER Granting 15 First Stipulation to Extend Time to File Motion for Summary Judgment. Plaintiff's Motions due by 4/18/2018. Signed by Judge James C. Mahan on 4/23/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-01017-JCM-VCF Document 15 Filed 04/20/18 Page 1 of 3

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Cyrus Safa
Attorney at Law: 13241
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
LEONARD STONE
Attorney At Law: 5791
Shook & Stone, Chtd.
710 South 4th Street
Las Vegas, NV 89101
TEL.: [phone]
FAX: [phone]
E-MAIL: [e-mail]

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Attorneys for Plaintiff
CORY D. MOORE

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CORY D. MOORE
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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.: 2:17-cv-01017-JCM-VCF
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR SUMMARY
JUDGMENT
(FIRST REQUEST)

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Plaintiff Cory D. Moore and Defendant Nancy A. Berryhill, Acting Commissioner
of Social Security, through their undersigned attorneys, stipulate, subject to this
court’s approval, to extend the time by 30 days from April 18, 2018 to May 18,
2018 for Plaintiff to file a motion for summary judgment, with all other
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Case 2:17-cv-01017-JCM-VCF Document 15 Filed 04/20/18 Page 2 of 3

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dates in the Court’s Order Concerning Review Of Social Security Cases extended

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accordingly. This is Plaintiff's first request for an extension.

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This request is made at the request of Plaintiff’s counsel to allow additional

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time to fully research the issues presented. The attorney responsible for writing

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this matter is involved in the preparation of three briefs to the Ninth Circuit, one

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finished last week, one due on Monday, and one due on Wednesday, all related

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cases that require coordinated briefing. The attorney responsible for this brief is

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also scheduled to present a paper at a conference in Atlanta on Friday, next week.

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DATE: April 18, 2018

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Mr. Cory D. Moore

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DATE: April 18, 2018

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DAYLE ELIESON
Interim United States Attorney
/s/ Sharon Lahey

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

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DATED: April 23, 2018

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IT IS SO ORDERED:

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UNITED STATES DISTRICT JUDGE JUDGE
UNITED STATES MAGISTRATE

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Case 2:17-cv-01017-JCM-VCF Document 15 Filed 04/20/18 Page 3 of 3

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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:17-CV-01017-JCM-VCF

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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 April 20, 2018.
I certify that all participants in the case are registered CM/ECF users and
that service will be accomplished by the CM/ECF system.

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/s/ Cyrus Safa
_______________________________
Cyrus Safa
Attorneys for Plaintiff

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