Cannon v. Berryhill

Filing 23

ORDER Granting 22 Stipulation for Extension of Time re 17 Motion to Remand to Agency (Third Request). Responses due by 1/29/2019. Signed by Magistrate Judge Carl W. Hoffman on 1/9/2019. (Copies have been distributed pursuant to the NEF - MR)

Case 2:18-cv-00470-KJD-CWH Document 22 Filed 01/08/19 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]
(THIRD 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 January 8, 2018 to
January 29, 2019. This is Defendant’s third request for extension. Good cause exists to grant
Defendant’s request for extension. On Christmas Day, Counsel’s family members were in a serious

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car accident that required hospitalization. As a result, Counsel was unexpectedly out of the office

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following the Christmas holiday. Counsel also has over 75+ active matters, which requires two or

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more dispositive motions a week until mid-March. Counsel also has a Ninth Circuit brief due on the

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same date as the current filing deadline. Due to Counsel’s heavy workload and unexpected leave,
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Case 2:18-cv-00470-KJD-CWH Document 22 Filed 01/08/19 Page 2 of 3

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Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff’s

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Motion for Summary Judgment. Defendant makes this request in good faith with no intention to

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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: January 8, 2019

/s/ *Cyrus Safa
(*as authorized by email on January 7, 2019)
CYRUS SAFA
Attorney for Plaintiff

Dated: January 8, 2019

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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January 9, 2019
DATED:_______________________

_________________________
HON. CARL J. HOFFMAN
UNITED STATES MAGISTRATE JUDGE

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Case 2:18-cv-00470-KJD-CWH Document 22 Filed 01/08/19 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 January 2019

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

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