Cannon v. Berryhill

Filing 16

ORDER Granting 15 Stipulation for Extension of Time to File Motion for Remand/Reversal (First Request). Motions due by 10/8/2018. Signed by Magistrate Judge Carl W. Hoffman on 9/10/2018. (Copies have been distributed pursuant to the NEF - MR)

Case 2:18-cv-00470-KJD-CWH Document 15 Filed 09/07/18 Page 1 of 3

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Cyrus Safa
Attorney at Law: 13241
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
PATRICK CANNON
Leonard Stone
Attorney at Law: 5791
Shook & Stone, Chtd.
710 South 4th Street
Las Vegas, NV 89101
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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PATRICK CANNON
Plaintiff,

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v.

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NANCY A. BERRYHILL,
Acting Commissioner of Social
Security,

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Defendant.

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Case No.: 2:18-cv-00470-KJD-CWH
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR
REMAND/REVERSAL
(FIRST REQUEST)

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Plaintiff Patrick Cannon and Defendant Nancy A. Berryhill, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,

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subject to this court’s approval, to extend the time from September 7, 2018 to

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October 8, 2018 for Plaintiff to file a Motion for Remand/Reversal, with all other
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Case 2:18-cv-00470-KJD-CWH Document 15 Filed 09/07/18 Page 2 of 3

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dates in the Court’s Order Concerning Review of Social Security Cases extended

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accordingly. This is Plaintiff's second request for an extension. This request is

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made at the request of Plaintiff’s counsel to allow additional time to fully research

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the issues presented. Due to heavy caseload, counsel is in the process of

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transferring cases internally and has ceased the intake of new cases to prevent

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future issues of sort.

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DATE: September 7, 2018

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Mr. Patrick Cannon

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DATE: September , 2018

DAYLE ELIESON
United States Attorney

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/s/ Tina Naicker

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BY: ____________________________
Tina Naicker
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
|*authorized by e-mail|

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DATED: September 10, 2018
IT IS SO ORDERED:
UNITED STATES MAGISTRATE JUDGE

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Case 2:18-cv-00470-KJD-CWH Document 15 Filed 09/07/18 Page 3 of 3

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CERTIFICATE OF SERVICE
FOR CASE NUMBER 2:18-CV-00470-KJD-CWH
I hereby certify that I electronically filed the foregoing with the Clerk of the
Court for this court by using the CM/ECF system on September 7, 2018
I certify that all participants in the case are registered CM/ECF users and
that service will be accomplished by the CM/ECF system.
/s/ Cyrus Safa
_______________________________
Cyrus Safa
Attorneys for Plaintiff

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