Niskar v. Berryhill

Filing 18

ORDER granting 17 Stipulation; Motion for Reversal/Remand due by 3/12/2018. Signed by Magistrate Judge Carl W. Hoffman on 3/5/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-02732-JCM-CWH Document 17 Filed 03/02/18 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]

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Gerald M. Welt
Attorney at Law: 1575
732 S. Sixth Street, Suite 200-D
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]; [e-mail]
Attorneys for Plaintiff
MICHAEL A. NISKAR

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MICHAEL A. NISKAR
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-02732-JCM-CWH
STIPULATION TO EXTEND TIME
TO FILE PLAINTIFF’S MOTION
FOR REVERSAL AND/OR REMAND
(FIRST REQUEST)

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Plaintiff Michael A. Niskar 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 10 days from March 2, 2018

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to March 12, 2018 for Plaintiff to file a motion for reversal and/or remand, with all

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other dates in the Court’s Order Concerning Review Of Social Security Cases

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Case 2:17-cv-02732-JCM-CWH Document 17 Filed 03/02/18 Page 2 of 3

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

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

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research the issues presented. Counsel makes the request due to an abnormally

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heavy briefing calendar. In the past week, Counsel has had four dispositive

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motions due. Additionally, Counsel attended a hearing yesterday which

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unexpectedly kept Counsel away from his office for most of the day, causing a

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delay in the completion of this motion. Counsel sincerely apologizes for any

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inconvenience this request may have on the Court and all parties involved.

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DATE: March 2, 2018

LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Mr. Michael A. Niskar

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Respectfully submitted,

DATE: March 2, 2018

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DAYLE ELIESON
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel
Social Security Administration

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/s/ Michael K. Marriott

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BY: ____________________________
Michael K. Marriott
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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DATED: March 5, 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-02732-JCM-CWH Document 17 Filed 03/02/18 Page 3 of 3

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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:17-CV-02732-JCM-CWH

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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 March 2, 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/ Cyrus Safa
_______________________________
Cyrus Safa
Attorneys for Plaintiff

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