Gonzalez v. Commissioner of Social Security Administration

Filing 17

ORDER granting 16 Motion to Extend Time; Motion for Reversal/Remand due by 7/9/2018. Signed by Magistrate Judge Peggy A. Leen on 6/18/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-03118-APG-PAL Document 16 Filed 06/13/18 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.: [phone]
Fax: [phone]
E-mail [e-mail]
Leonard Stone
Attorney at Law: 5791
Shook & Stone, Chtd.
710 South 4th Street
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
SONIA M. GONZALEZ

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SONIA M. GONZALEZ
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-03118-APG-PAL
UNOPPOSED MOTION TO EXTEND
TIME TO FILE MOTION FOR
REMAND AND/OR REVERSAL
(FIRST REQUEST)

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Plaintiff Sonia M. Gonzalez respectfully requests that the Court extend the

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time for Plaintiff to file her Motion for Reversal and/or Remand by 31 days from

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June 7, 2018 to July 9, 2018, with all other dates in the Court’s Order Concerning

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Review Of Social Security Cases extended accordingly. Of Counsel for Plaintiff

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Case 2:17-cv-03118-APG-PAL Document 16 Filed 06/13/18 Page 2 of 4

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has conferred with Defendant’s counsel, who has no opposition to this motion, on

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June 11, 2018.

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This is Plaintiff's first request for an extension. As the Court may be aware

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of Plaintiff's Of Counsel situation with other Social Security cases, Counsel's

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mother has been fighting a losing battle with Systemic Lupus Erythematosus that

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has required multiple surgeries these past two years due inflammation affecting the

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kidneys and lungs. On February 6, 2018, Of Counsel’s mother was taken to the

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emergency room and was admitted to the hospital. On February 8, 2018, Of

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Counsel's mother had a surgery to avoid further kidney obstruction due to the

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Lupus inflammation and kidney infection.

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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 Of Counsel has had to assist with. On March 28, 2018, Of

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Counsel’s mother was advised that another kidney surgery was medically

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necessary. On May 8, 2018, Of Counsel's mother had the first of three procedures

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to her kidney. On May 25, 2018, Of Counsel's mother was informed that the

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kidney infection is not curable, and the first of three kidney surgeries will take

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place July 17, 2018.

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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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Of Counsel was in the hospital with her husband on June 7, 2018 and required her

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attention for 24-hour watch due to the concussion.

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Case 2:17-cv-03118-APG-PAL Document 16 Filed 06/13/18 Page 3 of 4

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This is not an ordinary circumstance for Of Counsel and Of Counsel
sincerely apologizes to the Court for any inconvenience this may have cause.
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DATE: June 11, 2018

LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff SONIA M. GONZALEZ

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Respectfully submitted,

Of Counsel:
Monica Perales
Attorney at Law
DATED: June 18, 2018
IT IS SO ORDERED:
UNITED STATES MAGISTRATE JUDGE

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Case 2:17-cv-03118-APG-PAL Document 16 Filed 06/13/18 Page 4 of 4

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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:17-CV-03118-APG-PAL
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 June 13, 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.
/s/ Monica Perales
_______________________________
Monica Perales
Attorneys for Plaintiff

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