Leonardo v. Berryhill

Filing 22

ORDER Granting 21 Second Stipulation for Extension of Time Re: 18 Motion to Remand to Agency. Responses due by 8/29/2018. Signed by Magistrate Judge Carl W. Hoffman on 8/17/2018. (Copies have been distributed pursuant to the NEF - SLD)

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DAYLE ELIESON
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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LESLIE R. LEONARDO
Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:18-cv-00279-CWH
JOINT STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO PLAINTIFF’S
MOTION FOR

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that
the time for responding to Plaintiff’s Motion for Summary Judgment be extended from August 15,

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2018 to August 29, 2018. This is Defendant’s second request for extension. Good cause exists to

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grant Defendant’s request for extension. Counsel had another death in her family as well as a family

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medical emergency of an immediate family member. Counsel also has over 85+ pending social

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security cases, which require two or more dispositive motions a week until mid-September, a pending
Ninth Circuit matter, and several non-litigation civil rights and representative misconduct matters that
require prompt attention and investigation. Due to current workload demands and unanticipated leave,

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Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff’s

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Motion for Remand. 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
accordingly.

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Respectfully submitted,

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Dated: August 15, 2018

/s/ *Edward A. Wicklund
(*as authorized by email on August 15, 2018)
EDWARD A. WICKLUND
Attorney for Plaintiff

Dated: August 15, 2018

DAYLE ELIESON
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:
August 17, 2018
DATED:_______________________

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HON. CARL W. HOFFMAN
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 FOR

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

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the method of service identified below:

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CM/ECF:
Edward A. Wicklund
Olinsky Law Group
300 S. State St., Ste. 420
Syracuse, NY 13202
315-701-5780
Fax: [phone]
Email: [e-mail]

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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
775-825-2223
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff

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Respectfully submitted this 15th day of August 2018,

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

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