Carroll v. Commissioner of Social Security

Filing 19

ORDER granting ECF No. 18 Stipulation : Response to ECF No. 13 Motion to Remand due by 3/9/2018. Signed by Magistrate Judge Peggy A. Leen on 3/7/2018. (Copies have been distributed pursuant to the NEF - DRM)

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DAYLE ELIESON
Acting United States Attorney
District of Nevada
TINA 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]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SHERMAINE CARROLL,
Plaintiff,

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v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:17-cv-02237-MMD-PAL
JOINT STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S MOTION FOR
REVERSAL OR REMAND

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that

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the time for responding to Plaintiff’s Motion for Reversal and/or Remand be extended for one week

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from March 2, 2018 to March 9, 2018. This is Defendant’s third request for extension. Good cause

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exists to grant Defendant’s request for extension. Counsel for Defendant has a debilitating migraine

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that impairs her vision on the date of the current filing deadline. In addition, Counsel has over 75+
active pending matters, of which require 2+ dispositive motions until mid April. Counsel also has
three pending Ninth Circuit matters which require additional levels of review due in early March. Due

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to unanticipated leave and high workload demands, Counsel needs additional time to properly respond

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to Plaintiff’s Motion for Summary Judgment. Counsel apologizes for the belated request but did not

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anticipate being out on leave due to her debilitating migraine. Defendant makes this request in good
faith with no intention to unduly delay the proceedings. The parties further stipulate that the Court’s
Scheduling Order shall be modified accordingly.
Respectfully submitted,

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Dated: March 2, 2018

/s/ *Cyrus Safa
(*as authorized by email on March 2, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: March 2, 2018

DAYLE ELIESON
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

APPROVED AND SO ORDERED:

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March 7, 2018
DATED:_______________________

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THE HONORABLE PEGGY A. LEEN
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

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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO

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RESPOND TO PLAINTIFF’S MOTION FOR REVERSAL OR REMAND on the date and via

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the method of service identified below:

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CM/ECF:
Cyrus Safa
Law Offices of Lawrence D. Rohlfing
12631 E. Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
562-868-5886
Fax: [phone]
Email: [e-mail]
Gerald Welt
Gerald M. Welt, Chtd.
703 S. 8th St.
Las Vegas, NV 89101
702-382-2030
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
Respectfully submitted this 2nd day of March 2018,

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

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