Carroll v. Commissioner of Social Security

Filing 21

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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1 2 3 4 5 6 7 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 8 9 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 SHERMAINE CARROLL, Plaintiff, 13 14 15 16 17 v. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) ) ) ) ) ) ) ) ) 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 18 19 IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that 20 the time for responding to Plaintiff’s Motion for Reversal and/or Remand be extended for two business 21 days from March 9, 2018 to March 13, 2018. This is Defendant’s fourth request for extension. Good 22 cause exists to grant Defendant’s request for extension. Counsel for Defendant is out sick on the date 23 24 25 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 26 -1- 1 proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified 2 accordingly. 3 Respectfully submitted, 4 5 6 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 7 8 9 10 11 12 13 By 14 15 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant 16 ORDER 17 18 APPROVED AND SO ORDERED: 19 20 21 22 March 13, 2018 DATED:_______________________ ___________________________________ THE HONORABLE PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE 23 24 25 26 -2- 1 CERTIFICATE OF SERVICE 2 I, TINA L. NAICKER, certify that the following individual was served with a copy of the 3 JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO 4 RESPOND TO PLAINTIFF’S MOTION FOR REVERSAL OR REMAND on the date and via 5 the method of service identified below: 6 7 8 9 10 11 12 13 14 15 16 17 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, 18 19 20 /s/ Tina L. Naicker TINA L. NAICKER Special Assistant United States Attorney 21 22 23 24 25 26 -3-

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