Randolph v. Berryhill

Filing 21

ORDER Granting 20 Joint Stipulation for Extension of Time re 15 Motion to Remand to Agency (Third Request). Responses due by 12/13/2018. Signed by Magistrate Judge Peggy A. Leen on 12/4/2018. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5
6
7

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

8
9
10

UNITED STATES DISTRICT COURT

11

DISTRICT OF NEVADA

12

SHARONE RANDOLPH,
Plaintiff,

13
14
15
16
17
18
19
20
21
22

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

)
)
)
)
)
)
)
)
)
)

Case No. 2:18-cv-00555-JAD-PAL
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 November 29, 2018 to
December 13, 2018. This is Defendant’s third request for extension. Good cause exists to grant
Defendant’s request for extension. Counsel has a family emergency on the date of the current filing

23

deadline. Counsel also has over 75+ active matters, which requires two or more dispositive motions a

24

week until mid-January. In addition, Counsel has active civil rights and representative misconduct

25

matters that require immediate investigation. Counsel also has a Ninth Circuit brief due next week,

26

which requires multiple levels of review. Due to Counsel’s unexpected leave, Counsel became behind
-1-

1

on her heavy workload. As such, Counsel needs additional time to adequately review the transcript

2

and properly respond to Plaintiff’s Motion for Summary Judgment. Defendant makes this request in

3
4
5

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,

6
7

Dated: November 29, 2018

/s/ *Cyrus Safa
(*as authorized by email on November 29, 2018)
CYRUS SAFA
Attorney for Plaintiff

Dated: November 29, 2018

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

8
9
10
11
12
13
14
By

15
16
17
18
19

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

APPROVED AND SO ORDERED:

20
21
22
23

December 4, 2018
DATED:_______________________

_________________________
HON. PEGGY A. LEEN
UNITED STATES MAGISTRATE JUDGE

24
25
26

-2-

1

CERTIFICATE OF SERVICE

2

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

3

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

4

and via the method of service identified below:

5
6
7
8
9
10
11
12
13
14
15
16

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 29th day of November 2018,

17
18
19

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

20
21
22
23
24
25
26

-3-