Rael v. Berryhill

Filing 19

ORDER Granting 18 Unopposed Motion for Extension of Time. See Order for deadlines. Signed by Magistrate Judge Cam Ferenbach on 11/20/2017. (Copies have been distributed pursuant to the NEF - ADR)

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STEVEN W. MYHRE, CSBN 9635
Acting United States Attorney
GINA TOMASELLI
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
DISTRICT OF NEVADA – LAS VEGAS DIVISION

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JERRI L. RAEL,

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Plaintiff,

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vs.

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

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CIVIL NO. 2:17-cv-00947-GMN-VCF
DEFENDANT’S UNOPPOSED
MOTION FOR EXTENSION OF
TIME (FIRST REQUEST)

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IT IS HEREBY STIPULATED, by and between Jerri L. Rael (Plaintiff) and Nancy A. Berryhill,

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Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record,

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that Defendant shall have an extension of time of forty-five (45) days to deliver her Motion for

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Summary Judgment and in Opposition to Plaintiff’s Motion for Summary Judgment. The current due

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date is November 20, 2017. The new due date will be January 4, 2018. The parties further stipulate that

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all other dates will be extended accordingly, and Plaintiff’s reply will be due to Defendant by January
24, 2018.
This is the first extension of time requested by Defendant in the above-captioned matter.
Defendant requests this extension because the attorney responsible for briefing this case was only
recently assigned this case, has an unusually heavy workload this month, and is taking some leave time
during the upcoming holidays. This request is made in good faith with no intention to unduly delay the
Stip. & Prop. Order for Ext.; 2:17-cv-00947-GMN-VCF

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proceedings. Counsel for Defendant conferred with Plaintiff’s counsel, Mark Barrett, who has no
opposition to this motion, on November 16, 2017. It is therefore respectfully requested that Defendant
be granted a forty-five (45) day extension of time to respond to Plaintiff’s motion, up to and including
January 4, 2018.

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Respectfully submitted,
Dated: November 16, 2017

By: /s/ Mark D. Barrett *
MARK D. BARRETT
(*by email authorization on 11/16/17)

Dated: November 16, 2017

STEVEN W. MYHRE
Acting United States Attorney

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By: /s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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Attorneys for Defendant

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IT IS SO ORDERED:
__________________________________
THE HONORABLE CAM FERENBACH
UNITED STATES MAGISTRATE JUDGE
11-20-2017
DATE:__________________________

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Stip. & Prop. Order for Ext.; 2:17-cv-00947-GMN-VCF

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IT IS HEREBY CERTIFIED THAT:
I, Gina Tomaselli, certify that the following individual(s) were served with a copy of the
foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method
of service identified below:

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CM/ECF:

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Mark D. Barrett
Osterhout Berger Disability Law, LLC
521 Cedar Way, Ste. 200
Oakmont, PA 15139
412-794-8003
Fax: [phone]
Email: [e-mail]

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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
Email: [e-mail]
I declare under penalty of perjury that the foregoing is true and correct.
Dated: November 16, 2017

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STEVEN W. MYHRE
Acting United States Attorney
By: /s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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Attorneys for Defendant

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Stip. & Prop. Order for Ext.; 16-cv-1181-JCM-CWH