Cannon v. Berryhill

Filing 19

ORDER Granting 18 Stipulation for Extension of Time re 17 Motion to Remand to Agency (First Request). Responses due by 12/8/2018. Signed by Magistrate Judge Carl W. Hoffman on 11/13/2018. (Copies have been distributed pursuant to the NEF - MR)

Case 2:18-cv-00470-KJD-CWH Document 18 Filed 11/07/18 Page 1 of 3

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DAYLE ELIESON
United States Attorney
District of Nevada
TINA NAICKER, CSBN 252766
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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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.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:18-cv-00470-KJD-CWH
JOINT STIPULATION FOR EXTENSION OF
TIME AND [PROPOSED ORDER]
(FIRST REQUEST)

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that
the time for responding to Plaintiff’s Motion for Remand be extended from November 8, 2018 to
December 8, 2018. This is Defendant’s first request for extension. Good cause exists to grant
Defendant’s request for extension. Counsel was out of the office for nearly three weeks on

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intermittent sick leave for the flu/acute pneumonia. Counsel also had a migraine for the last two days

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which impairs her vision. Counsel also has over 75+ active matters, which requires two or more

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dispositive motions a week until late-December. In addition, Counsel has active civil rights and

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representative misconduct matters that require immediate investigation. Counsel also has a Ninth
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Case 2:18-cv-00470-KJD-CWH Document 18 Filed 11/07/18 Page 2 of 3

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Circuit brief due in mid-November, which requires multiple levels of review. Due to Counsel’s

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unexpected leave and heavy workload, Counsel needs additional time to adequately review the

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transcript and properly respond to Plaintiff’s Motion for Remand. Defendant makes this request 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.
Respectfully submitted,

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Dated: November 7, 2018

/s/ *Cyrus Safa
(*as authorized by email on November 6, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: November 7, 2018

DAYLE ELIESON
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

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APPROVED AND SO ORDERED:

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November 13, 2018
DATED:_______________________

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HON. CARL J. HOFFMAN
UNITED STATES MAGISTRATE JUDGE

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Case 2:18-cv-00470-KJD-CWH Document 18 Filed 11/07/18 Page 3 of 3

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CERTIFICATE OF SERVICE

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I, TINA L. NAICKER, certify that the following individual was served with a copy of the

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JOINT STIPULATION FOR EXTENSION OF TIME AND [PROPOSED ORDER] on the date

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and via the method of service identified below:
CM/ECF:
Cyrus Safa
Law Offices of Lawrence D. Rohlfing
12631 E. Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
562-868-5886
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff
Respectfully submitted this 7th day of November 2018,

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney

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