Vandiver v. Berryhill
Filing
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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)
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
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Telephone: (415) 268-5602
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Facsimile: (415) 744-0134
E-Mail: Gina.Tomaselli@ssa.gov
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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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)
ROSA G. VANDIVER,
) Case No.: 2:18-cv-00362-JAD-CWH
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Plaintiff,
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) DEFENDANT’S UNOPPOSED MOTION
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v.
) FOR EXTENSION OF TIME
)
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NANCY A. BERRYHILL,
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Acting Commissioner of Social Security,
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Defendant.
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)
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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
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.
2 Dated: July 12, 2018
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By: /s/ Marc V. Kalagian*
MARC V. KALAGIAN
Rohlfing & Kalagian, LLP
Attorney for Plaintiff
(*As authorized via email on 7/12/18)
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6 Dated: July 12, 2018
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DAYLE ELIESON
United States Attorney
/s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney
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IT IS SO ORDERED:
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__________________________________
THE HONORABLE CARL W. HOFFMAN
UNITED STATES MAGISTRATE JUDGE
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July 16, 2018
DATE: __________________________
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Stip & Proposed Order for Ext; 18-362
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Case 2:18-cv-00362-CWH Document 20 Filed 07/12/18 Page 3 of 3
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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:
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Marc V Kalagian
7 Rohlfing & Kalagian, LLP
211 E. Ocean Blvd.
8 Suite 420
Long Beach, CA 90802
9 Email: marc.kalagian@rksslaw.com
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11 I declare under penalty of perjury that the foregoing is true and correct.
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14 Dated: July 12, 2018
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DAYLE ELIESON
United States Attorney
District of Nevada
By: /s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney
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Attorneys for Defendant
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Stip & Proposed Order for Ext; 18-362
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