Vandiver v. Berryhill

Filing 23

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)

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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 5 San Francisco, California 94105 Telephone: (415) 977-8938 6 Facsimile: (415) 744-0134 E-Mail: Theophous.Reagans@ssa.gov 7 8 Attorneys for Defendant UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 ROSA G. VANDIVER, Plaintiff, v. NANCY A. BERRYHILL, Acting Commissioner of Social Security, Defendant. ) ) Case No.: 2:18-cv-00362-JAD-CWH ) ) DEFENDANT’S UNOPPOSED MOTION ) FOR EXTENSION OF TIME ) ) ) ) ) ) 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. 2 . 3 Dated: August 28, 2018 4 5 By: /s/ Marc V. Kalagian* MARC V. KALAGIAN Rohlfing & Kalagian, LLP Attorney for Plaintiff (*As authorized via email on 8/28/18) 6 7 Dated: August 28, 2018 8 DAYLE ELIESON United States Attorney /s/ Patrick W. Snyder PATRICK WILLIAM SNYDER Special Assistant United States Attorney 9 10 11 /s/ Theophous H. Reagans THEOPHOUS H. REAGANS Special Assistant United States Attorney 12 13 14 15 IT IS SO ORDERED: 16 __________________________________ THE HONORABLE CARL W. HOFFMAN UNITED STATES MAGISTRATE JUDGE 17 18 August 30, 2018 DATE: __________________________ 19 20 21 22 23 24 25 26 Stip & Proposed Order for Ext; 18-362 2 Case 2:18-cv-00362-CWH Document 22 Filed 08/29/18 Page 3 of 3 1 IT IS HEREBY CERTIFIED THAT: 2 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: 7 Marc V Kalagian 8 Rohlfing & Kalagian, LLP 211 E. Ocean Blvd. 9 Suite 420 Long Beach, CA 90802 10 Email: marc.kalagian@rksslaw.com 11 12 I declare under penalty of perjury that the foregoing is true and correct. 13 14 15 Dated: July 12, 2018 16 17 DAYLE ELIESON United States Attorney District of Nevada By: /s/ Theophous H. Reagans THEOPHOUS H. REAGANS Special Assistant United States Attorney 18 19 Attorneys for Defendant 20 21 22 23 24 25 26 Stip & Proposed Order for Ext; 18-362 3

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