Cannon v. Berryhill

Filing 21

ORDER Granting 20 Stipulation for Extension of Time re 17 Motion to Remand to Agency (Second Request). Responses due by 1/8/2019. Signed by Magistrate Judge Carl W. Hoffman on 11/27/2018. (Copies have been distributed pursuant to the NEF - MR)

Case 2:18-cv-00470-KJD-CWH Document 20 Filed 11/26/18 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]
(SECOND 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 December 8, 2018 to
January 8, 2019. This is Defendant’s second request for extension. Good cause exists to grant
Defendant’s request for extension. Counsel respectfully requests additional time due to her heavy

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caseload and upcoming leave. Counsel also has over 75+ active matters, which requires two or more

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dispositive motions a week until mid-January. 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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Circuit brief due the same week as the current deadline, which requires multiple levels of review.
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Case 2:18-cv-00470-KJD-CWH Document 20 Filed 11/26/18 Page 2 of 3

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Counsel is also expected to be on leave during the first week of December. As such, Counsel needs

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additional time to adequately review the transcript and properly respond to Plaintiff’s Motion for

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Summary Judgment. 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.

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Respectfully submitted,

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Dated: November 26, 2018

/s/ *Cyrus Safa
(*as authorized by email on November 26, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: November 26, 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

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ORDER

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APPROVED AND SO ORDERED:

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November 27, 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 20 Filed 11/26/18 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 26th day of November 2018,

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

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