Carroll v. Commissioner of Social Security
Filing
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ORDER granting ECF No. 20 Stipulation for Extension of Time to respond to ECF No. 13 Motion to Remand to Agency. Response due by 3/13/2018. Signed by Judge Miranda M. Du on 3/13/2018. (Copies have been distributed pursuant to the NEF - KW)
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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: (415) 268-5611
Facsimile: (415) 744-0134
E-Mail: Tina.Naicker@SSA.gov
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 two business
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days from March 9, 2018 to March 13, 2018. This is Defendant’s fourth request for extension. Good
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cause exists to grant Defendant’s request for extension. Counsel for Defendant is out sick on the date
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of the current filing deadline. Counsel apologizes for the belated request but did not anticipate being
out on sick leave. Defendant makes this request in good faith with no intention to unduly delay the
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proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified
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accordingly.
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Respectfully submitted,
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Dated: March 9, 2018
/s/ *Cyrus Safa
(*as authorized by email on March 9, 2018)
CYRUS SAFA
Attorney for Plaintiff
Dated: March 9, 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
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ORDER
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APPROVED AND SO ORDERED:
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March 13, 2018
DATED:_______________________
___________________________________
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: 562-868-5491
Email: cyrus.safa@rohlfinglaw.com
Gerald Welt
Gerald M. Welt, Chtd.
703 S. 8th St.
Las Vegas, NV 89101
702-382-2030
Fax: 702-684-5157
Email: gmwesq@weltlaw.com
Attorneys for Plaintiff
Respectfully submitted this 9th day of March 2018,
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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney
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