Pagel v. Commissioner of Social Security

Filing 22

ORDER granting 21 Stipulation; Motion for Reversal/Remand due by 12/1/2017. Signed by Magistrate Judge Nancy J. Koppe on 11/21/2017. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-01547-APG-NJK Document 21 Filed 11/20/17 Page 1 of 3

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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]
Gerald M. Welt
Attorney at Law: 1575
703 S. Eight St.
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]
Attorneys for Plaintiff
ROXANNE J. PAGEL

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ROXANNE J. PAGEL
v.

Plaintiff,

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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-1547-APG-NJK
STIPULATION AND [PROPOSED]
ORDER FOR AN EXTENSION OF
TIME TO FILE MOTION FOR
REVERSAL AND/OR REMAND
(FIRST REQUEST)

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Plaintiff Roxanne J. Pagel and Defendant Nancy A. Berryhill, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,

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subject to this court’s approval, to extend the time by 14 days from November 17,

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2017 to December 1, 2017 for Plaintiff to file a motion for reversal and/or remand,

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with all other dates in the Court’s Order Concerning Review Of Social Security
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Case 2:17-cv-01547-APG-NJK Document 21 Filed 11/20/17 Page 2 of 3

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

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

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research the issues presented. Specifically, Counsel requires additional time due to

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the press of business. Counsel has attended two hearings this week and had three

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opening briefs scheduled for the week. Counsel intended on maintaining the

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briefing calendar; however, Counsel now requests additional time in order to

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properly and competently address the issues in this case.

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DATE: November 17, 2017

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Roxanne J. Pagel

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DATE: November 17, 2017

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STEVEN W. MYHRE
Acting United States Attorney

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/s/ Carolyn B. Chen

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

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DATED: November 21, 2017
IT IS SO ORDERED:
UNITED STATES MAGISTRATE JUDGE

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