Randolph v. Berryhill

Filing 17

ORDER Granting 16 Joint Stipulation for Extension of Time re 15 Motion to Remand to Agency (First Request). Responses due by 10/29/2018. Signed by Magistrate Judge Peggy A. Leen on 9/17/2018. (Copies have been distributed pursuant to the NEF - MR)

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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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)
) Case No. 2:18-cv-00555-JAD-PAL
)
Plaintiff,
)
) JOINT STIPULATION FOR EXTENSION OF
v.
) TIME AND [PROPOSED ORDER]
NANCY A. BERRYHILL,
)
Acting Commissioner of Social Security,
)
)
Defendant.
)
IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that

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the time for responding to Plaintiff’s Motion for Remand be extended from September 13, 2018 to

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SHARONE RANDOLPH,

October 29, 2018. This is Defendant’s first request for extension. Good cause exists to grant
Defendant’s request for extension. Counsel was recently out on intermittent medical leave and
bereavement leave for the past few months. Counsel has over 75+ active matters, which requires two

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or more dispositive motions a week until mid-September. In addition, Counsel has active civil rights

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and representative misconduct matters that require immediate investigation. Counsel also has a Ninth

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Circuit brief due on October 1, 2018, which requires multiple levels of review. Due to Counsel’s

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unexpected leave, Counsel became behind on her heavy workload. As such, Counsel needs additional
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time to adequately review the transcript and properly respond to Plaintiff’s Motion for Summary

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Judgment. Counsel for Defendant is also expected to be out of the office from September 3, 2018

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through September 9, 2018 and September 21, 2018 through September 27, 2018. 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: September 13, 2018

/s/ *Cyrus Safa
(*as authorized by email on September 13, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: September 13, 2018

MCGREGOR W. SCOTT
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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September 17, 2018
DATED:_______________________

_________________________
HON. PEGGY A. LEEN
UNITED STATES MAGISTRATE JUDGE

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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:

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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]
Gerald Welt
Gerald M. Welt, Chtd.
703 S. 8th St.
Las Vegas, NV 89101
702-382-2030
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
Respectfully submitted this 13th day of September 2018,

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

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