Vandiver v. Berryhill
Filing
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ORDER granting 22 Motion to Extend Time; Re: 18 Motion to Remand to Agency. Responses due by 9/30/2018. Signed by Magistrate Judge Carl W. Hoffman on 8/30/2018. (Copies have been distributed pursuant to the NEF - JM)
Case 2:18-cv-00362-CWH Document 22 Filed 08/29/18 Page 1 of 3
1 DAYLE ELIESON
United States Attorney
2 PATRICK W. SNYDER, CSBN 260690
3 Special Assistant United States Attorney
THEOPHOUS H. REAGANS, CSBN 189450
4 Special Assistant United States Attorney
160 Spear Street, Suite 800
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San Francisco, California 94105
Telephone: (415) 977-8938
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Facsimile: (415) 744-0134
E-Mail: Theophous.Reagans@ssa.gov
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8 Attorneys for Defendant
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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ROSA G. VANDIVER,
Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.
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) Case No.: 2:18-cv-00362-JAD-CWH
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) DEFENDANT’S UNOPPOSED MOTION
) FOR EXTENSION OF TIME
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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 thirty (30) days to file her
Opposition to Plaintiff’s Motion for Summary Judgment. The current due date is August 30, 2018.
The new date will be September 30, 2018. An extension of time is needed because the attorney
responsible for briefing this case continues to undergo medical treatment, requiring her to take medical
leave. This motion is being filed by her supervisor because she is currently unable to work on her
cases. This is the second extension of time requested by Defendant in the above referenced case. This
request is made in good faith with no intention to unduly delay the proceedings. The parties further
Case 2:18-cv-00362-CWH Document 22 Filed 08/29/18 Page 2 of 3
1 stipulate that the Court’s Scheduling Order shall be modified accordingly.
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3 Dated: August 28, 2018
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By: /s/ Marc V. Kalagian*
MARC V. KALAGIAN
Rohlfing & Kalagian, LLP
Attorney for Plaintiff
(*As authorized via email on 8/28/18)
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7 Dated: August 28, 2018
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DAYLE ELIESON
United States Attorney
/s/ Patrick W. Snyder
PATRICK WILLIAM SNYDER
Special Assistant United States Attorney
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/s/ Theophous H. Reagans
THEOPHOUS H. REAGANS
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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August 30, 2018
DATE: __________________________
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Stip & Proposed Order for Ext; 18-362
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Case 2:18-cv-00362-CWH Document 22 Filed 08/29/18 Page 3 of 3
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IT IS HEREBY CERTIFIED THAT:
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I, Theophous H. Reagans, certify that the following individual(s) were served with a copy of
3 the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the
4 method
5 of service identified below:
6 CM/ECF:
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Marc V Kalagian
8 Rohlfing & Kalagian, LLP
211 E. Ocean Blvd.
9 Suite 420
Long Beach, CA 90802
10 Email: marc.kalagian@rksslaw.com
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12 I declare under penalty of perjury that the foregoing is true and correct.
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Dated: July 12, 2018
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DAYLE ELIESON
United States Attorney
District of Nevada
By: /s/ Theophous H. Reagans
THEOPHOUS H. REAGANS
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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