Clemons v. Berryhill

Filing 15

ORDER Granting 14 First Stipulation for Extension of Time to File Motion for Remand. Motions due by 1/7/2019. Signed by Magistrate Judge Peggy A. Leen on 12/21/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:18-cv-00824-JAD-PAL Document 14 Filed 11/30/18 Page 1 of 4

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Cyrus Safa
Nevada Bar No.: 13241
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
WANDA R. CLEMONS

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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WANDA R. CLEMONS
Plaintiff,

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v.

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NANCY A. BERRYHILL,
Acting Commissioner of Social
Security,

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Defendant.

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Case No.: 2:18-cv-00824-JAD-PAL
STIPULATION TO EXTEND TIME
TO FILE MOTION FOR REMAND
(FIRST REQUEST)

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Plaintiff Wanda R. Clemons and Defendant Nancy A. Berryhill, Acting

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Commissioner of Social Security, through their undersigned attorneys, stipulate,

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subject to this court’s approval, to extend the time by 45 days from November 23,

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2018 to January 7, 2019 for Plaintiff to file a Motion for Remand, with all other

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dates in the Court’s Scheduling order extended accordingly. This is Plaintiff's first

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request for an extension. This request is made at the request of Plaintiff’s counsel

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to allow additional time to fully research the issues presented. Counsel's mother

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has been fighting a losing battle with Systemic Lupus Erythematosus that has

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Case 2:18-cv-00824-JAD-PAL Document 14 Filed 11/30/18 Page 2 of 4

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required multiple surgeries these past two years due inflammation affecting the

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kidneys and lungs. Counsel’s mother has undergone several kidney surgeries since

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February 11, 2018. Counsel’s mother continues with her recovery process that has

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required Counsel to take time off to attend her mother’s financial and physical

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needs which has impacted a heavy briefing and hearing calendar. In addition,

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Counsel has been fighting off a flu for since last week.

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This is not an ordinary circumstance for Counsel and Counsel sincerely

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apologizes to the Court for any inconvenience this may have cause. Counsel’s firm

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has hired another associate to help Counsel during this difficult time. Counsel

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sincerely apologizes to the court and its staff for any inconvenience this may have.

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DATE: November 29, 2018

Respectfully submitted,
LAWRENCE D. ROHLFING

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/s/ Cyrus Safa

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BY: _______________________
Cyrus Safa
Attorney for plaintiff Wanda R. Clemons

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DATE: November 29, 2018
DAYLE ELIESON
United States Attorney

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/s/ Asim Modi
BY: ____________________________
Asim Modi
Special Assistant United States Attorney
Attorneys for defendant Nancy A. Berryhill
Acting Commissioner of Social Security
|*authorized by e-mail|

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IT IS SO ORDERED this 21st day of December, 2018.

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______________________________
Peggy A. Leen
United States Magistrate Judge

Case 2:18-cv-00824-JAD-PAL Document 14 Filed 11/30/18 Page 4 of 4

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CERTIFICATE OF SERVICE

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FOR CASE NUMBER E 2:18-CV-00824-JAD-PAL

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I hereby certify that I electronically filed the foregoing with the Clerk of the
Court for this court by using the CM/ECF system on November 29, 2018.

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I certify that all participants in the case are registered CM/ECF users and
that service will be accomplished by the CM/ECF system.
/s/ Cyrus Safa
_______________________________
Cyrus Safa
Attorneys for Plaintiff

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