Nelson v. Colvin

Filing 23

ORDER Granting 22 Motion to Extend Time re 20 Motion to Remand. (Responses due by 12/13/2017.) Signed by Magistrate Judge Carl W. Hoffman on 11/8/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02402-JCM-CWH Document 22 Filed 11/07/17 Page 1 of 3

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STEVEN W. MYHRE
Acting United States Attorney
District of Nevada

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CYNTHIA B. DE NARDI
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DESIREE NELSON,

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Plaintiff,

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v.

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

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) Case No.: 2:16-cv-02402-JCM-CWH
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UNOPPOSED MOTION FOR
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EXTENSION OF TIME
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(FIRST REQUEST)
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Opposition to Plaintiff’s

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Motion for Remand, due on November 13, 2017, by 30 days, through and including December 13, 2017.

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An extension of time is needed in order to prepare Defendant’s Opposition because the

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undersigned counsel is involved in preparations for two evidentiary hearings in labor and employment

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litigation matters, and requires additional time to adequately research and prepare the issues presented

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by Plaintiff in motion to remand. This request is made in good faith with no intention to unduly delay

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the proceedings.

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Case 2:16-cv-02402-JCM-CWH Document 22 Filed 11/07/17 Page 2 of 3

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Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion,
on November 7, 2017.
Respectfully submitted this 7th day of November 2017.

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STEVEN W. MYHRE
Acting United States Attorney

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/s/ Cynthia B. De Nardi
CYNTHIA B. DE NARDI
Special Assistant United States Attorney

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OF COUNSEL:
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED: November 8, 2017

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Case 2:16-cv-02402-JCM-CWH Document 22 Filed 11/07/17 Page 3 of 3

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CERTIFICATE OF SERVICE
I, Cynthia B. De Nardi, certify that the following individual was served with a copy of the
UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service
identified below:
CM/ECF:
Mark D. Barrett
Osterhout Disability Law, LLC
521 Cedar Way, Ste. 200
Oakmont, PA 15139
[e-mail]

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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
[e-mail]

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Dated this 7th day of November 2017.

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/s/ Cynthia B. De Nardi
CYNTHIA B. DE NARDI
Special Assistant United States Attorney

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