Disney v. Saul, 2:18-cv-01648-GMN-CWH. (2019)
Court: District Court, D. Nevada
Number: infdco20190724c87
Visitors: 34
Filed: Jul. 23, 2019
Latest Update: Jul. 23, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE CROSS-MOTION TO AFFIRM AND/OR RESPOND TO PLAINITFF'S MOTION FOR REMAND. (Second Request) CARL W. HOFFMAN , District Judge . 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 July 19, 2019 to July 26, 2019. This is Defendant's second request for extension. Good cause exists to grant Defendant's request for exten
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE CROSS-MOTION TO AFFIRM AND/OR RESPOND TO PLAINITFF'S MOTION FOR REMAND. (Second Request) CARL W. HOFFMAN , District Judge . 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 July 19, 2019 to July 26, 2019. This is Defendant's second request for extension. Good cause exists to grant Defendant's request for extens..
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE CROSS-MOTION TO AFFIRM AND/OR RESPOND TO PLAINITFF'S MOTION FOR REMAND. (Second Request)
CARL W. HOFFMAN, District Judge.
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 July 19, 2019 to July 26, 2019. This is Defendant's second request for extension. Good cause exists to grant Defendant's request for extension. Counsel for Defendant was out of the office since the last extension request due to ongoing health issues from her chronic migraines, which impair her vision. In addition, Counsel also has over 100+ active social security matters, which require two or more dispositive motions until mid-September. Counsel also has three pending Ninth Circuit matters, which require several levels of review. As such, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Summary Judgment. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Counsel apologizes for the belated request, but made her request as soon as reasonably practicable following her leave.
Respectfully submitted,
Respectfully submitted,
Dated: July 19, 2019 /s/ John Shook
(*as authorized by email on July 19, 2019)
JOHN SHOOK
Attorney for Plaintiff
Dated: July 19, 2019 NICHOLAS A. TRUTANICH
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
By /s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER
APPROVED AND SO ORDERED.
Source: Leagle
