Costandi v. Commissioner of Social Security
Filing
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ORDER granting 18 Stipulation; Motion for Reversal/Remand due by 8/16/2018. Signed by Magistrate Judge Peggy A. Leen on 7/19/2018. (Copies have been distributed pursuant to the NEF - JM)
Case 2:17-cv-02019-JCM-PAL Document 18 Filed 07/18/18 Page 1 of 4
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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.: (562) 868-5886
Fax: (562) 868-5491
E-mail cyrus.safa@rohlfinglaw.com
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Leonard Stone
Attorney at Law: 5791
Shook & Stone, Chtd.
710 South 4th Street
Las Vegas, NV 89101
Tel.: (702) 385-2220
Fax: (702) 384-0394
E-mail: LMoreno@shookandstone.com
Attorneys for Plaintiff
NAIM R. COSTANDI
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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NAIM R. COSTANDI
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-02019-JCM-PA
UNOPPOSED MOTION TO EXTEND
TIME TO FILE MOTION FOR
REVERSAL AND/OR REMAND
(SECOND REQUEST)
Plaintiff Naim R. Costandi respectfully requests that the Court extend the
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time for Plaintiff to file her Motion for Reversal and/or Remand by 35 days from
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July 12, 2018 to August 16, 107, with all other dates in the Court’s Order
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Concerning Review Of Social Security Cases extended accordingly. Of Counsel
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for Plaintiff has conferred with Defendant’s counsel, who has no opposition to this
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motion, on July 12, 2018.
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Case 2:17-cv-02019-JCM-PAL Document 18 Filed 07/18/18 Page 2 of 4
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This is Plaintiff's second request for an extension. As the Court may be
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aware of Plaintiff's Of Counsel situation with other Social Security cases, Of
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Counsel's mother has been fighting a losing battle with Systemic Lupus
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Erythematosus that has required multiple surgeries these past two years due
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inflammation affecting the kidneys and lungs.
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On February 6, 2018, Of Counsel’s mother was taken to the emergency
room and was admitted to the hospital.
On February 8, 2018, Of Counsel's mother had a surgery to avoid further
kidney obstruction due to the Lupus inflammation and kidney infection.
On February 16, 2018, Of Counsel’s husband’s mother suffered two
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ischemic strokes, requiring 24-hour daily care for her activities of daily living up to
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present day, which Counsel has had to assist with.
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On March 28, 2018, Of Counsel’s mother was advised that another kidney
surgery was medically necessary.
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After consultations with different specialists during the month of April, on
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May 8, 2018, Of Counsel's mother had an out-patient procedure to her kidney to
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test if surgery was an option.
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On May 25, 2018, Of Counsel's mother was informed that the kidney
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infection is not curable, and that she is required to have at least three kidney
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surgeries or be placed on antibiotics for as long as her body could handle it. Due to
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the autoimmune disease, the latter is simply not an option.
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On June 7, 2018 at 3:30 a.m., Of Counsel’s husband suffered a micturition
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syncope resulting in a concussion, 17 staples to his head, and a blood transfusion.
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Counsel was in the hospital with her husband had to provide care for her husband
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for 24-hour watch due to the concussion.
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Case 2:17-cv-02019-JCM-PAL Document 18 Filed 07/18/18 Page 3 of 4
Of Counsel’s mother has the first of three kidney surgeries scheduled on
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July 17, 2018. Counsel needs to take additional time to place all her mother’s
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personal and financial matters in order.
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This is not an ordinary circumstance for Of Counsel and Of Counsel
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sincerely apologizes to the Court for any inconvenience this may have cause.
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Counsel’s firm has hired another associate to help Counsel during this difficult
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time.
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DATE: July 12, 2018
LAWRENCE D. ROHLFING
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/s/ Cyrus Safa
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BY: _______________________
Cyrus Safa
Attorney for plaintiff Mr. Naim R. Costandi
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Respectfully submitted,
Of Counsel:
Monica Perales
Attorney at Law
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DATED: July 19, 2018
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IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
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Case 2:17-cv-02019-JCM-PAL Document 18 Filed 07/18/18 Page 4 of 4
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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:17-CV-02019-JCM-PA
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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 July 12, 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/ Monica Perales
_______________________________
Monica Perales
Attorneys for Plaintiff
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