Vandiver v. Berryhill

Filing 21

ORDER granting 20 Motion to Extend Time; Re: 18 Motion to Remand to Agency. Responses due by 8/30/2018. Signed by Magistrate Judge Carl W. Hoffman on 7/16/2018. (Copies have been distributed pursuant to the NEF - JM)

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Case 2:18-cv-00362-CWH Document 20 Filed 07/12/18 Page 1 of 3 1 DAYLE ELIESON United States Attorney 2 GINA TOMASELLI, CSBN 267090 3 Special Assistant United States Attorney 160 Spear Street, Suite 800 San Francisco, California 94105 4 Telephone: (415) 268-5602 5 Facsimile: (415) 744-0134 E-Mail: Gina.Tomaselli@ssa.gov 6 Attorneys for Defendant 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 ) ROSA G. VANDIVER, ) Case No.: 2:18-cv-00362-JAD-CWH 10 Plaintiff, ) ) DEFENDANT’S UNOPPOSED MOTION 11 v. ) FOR EXTENSION OF TIME ) 12 NANCY A. BERRYHILL, ) Acting Commissioner of Social Security, ) 13 ) Defendant. ) 14 ) 15 16 17 18 19 20 21 22 23 24 25 26 IT IS HEREBY STIPULATED, by and between Rosa G. Vandiver (Plaintiff) and Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record, that Defendant shall have an extension of time of forty-five (45) days to file her Opposition to Plaintiff’s Motion for Summary Judgment. The current due date is July 16, 2018. The new date will be August 30, 2018. An extension of time is needed because the attorney responsible for briefing this case is still recovering from a medical procedure, requiring her to take medical leave, and is now facing a backlog of cases already on extension. This is the first extension of time requested by Defendant in the above. This request is made in good faith with no intention to unduly delay the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. Case 2:18-cv-00362-CWH Document 20 Filed 07/12/18 Page 2 of 3 1 . 2 Dated: July 12, 2018 3 4 By: /s/ Marc V. Kalagian* MARC V. KALAGIAN Rohlfing & Kalagian, LLP Attorney for Plaintiff (*As authorized via email on 7/12/18) 5 6 Dated: July 12, 2018 7 DAYLE ELIESON United States Attorney /s/ Gina Tomaselli GINA TOMASELLI Special Assistant United States Attorney 8 9 10 11 12 IT IS SO ORDERED: 13 __________________________________ THE HONORABLE CARL W. HOFFMAN UNITED STATES MAGISTRATE JUDGE 14 15 July 16, 2018 DATE: __________________________ 16 17 18 19 20 21 22 23 24 25 26 Stip & Proposed Order for Ext; 18-362 2 Case 2:18-cv-00362-CWH Document 20 Filed 07/12/18 Page 3 of 3 1 2 IT IS HEREBY CERTIFIED THAT: I, Gina Tomaselli, certify that the following individual(s) were served with a copy of the 3 foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method 4 of service identified below: 5 CM/ECF: 6 Marc V Kalagian 7 Rohlfing & Kalagian, LLP 211 E. Ocean Blvd. 8 Suite 420 Long Beach, CA 90802 9 Email: marc.kalagian@rksslaw.com 10 11 I declare under penalty of perjury that the foregoing is true and correct. 12 13 14 Dated: July 12, 2018 15 16 DAYLE ELIESON United States Attorney District of Nevada By: /s/ Gina Tomaselli GINA TOMASELLI Special Assistant United States Attorney 17 18 Attorneys for Defendant 19 20 21 22 23 24 25 26 Stip & Proposed Order for Ext; 18-362 3

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