Patterson v. Berryhill, 2:18-cv-01951-APG-PAL. (2019)
Court: District Court, D. Nevada
Number: infdco20190410e86
Visitors: 7
Filed: Apr. 04, 2019
Latest Update: Apr. 04, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDNAT TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND/REVERSAL PEGGY A. LEEN , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Opening Brief be extended from April 8, 2019 to May 15, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel was out of the off
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDNAT TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND/REVERSAL PEGGY A. LEEN , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Opening Brief be extended from April 8, 2019 to May 15, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel was out of the offi..
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR DEFENDNAT TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND/REVERSAL
PEGGY A. LEEN, Magistrate Judge.
IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for responding to Plaintiff's Opening Brief be extended from April 8, 2019 to May 15, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel was out of the office on intermittent sick leave for two and half weeks with the flu/pneumonia last month and was also subsequently out due to her chronic migraines, which impair her vision following her illness. Counsel also has over 80+ active social security matters, which require two or more dispositive motions per week until mid-May. Due to heavy caseload and unexpected leave, Counsel needs additional time to adequately review the transcript and properly respond to Plaintiff's Motion for Reversal and/or Remand. 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, as she has been out on sick leave.
Respectfully submitted,
Dated: April 4, 2019 /s/Cyrus Safa ___________________
(*as authorized by email on April 4, 2019)
CYRUS SAFA
Attorney for Plaintiff
Dated: April 4, 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
