Williams v. Nancy A. Berryhill

Filing 17

ORDER Granting 16 Motion to Extend Time to Respond re 15 Motion to Remand to Agency. Responses due by 9/18/2017. Signed by Magistrate Judge Cam Ferenbach on 8/14/17. (Copies have been distributed pursuant to the NEF - MMM)

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STEVEN W. MYHRE, NVBN 9635
United States Attorney
District of Nevada
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
160 Spear Street, Suite 800
Telephone No. [phone]
Facsimile No. [phone]
Email Address: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ROBYN ANN WILLIAMS,

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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. 2:17-CV-01036-JAD-VCF
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UNOPPOSED MOTION FOR
) EXTENSION OF TIME AND PROPOSED
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ORDER
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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 response to Plaintiff’s

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motion for summary judgment and cross motion for summary judgment, due on August 17, 2017, by 32

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days, through and including September 18, 2017.

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An extension of time is needed in order to prepare Defendant’s response and cross motion

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because the undersigned’s elderly mother has had a medical emergency and has been hospitalized today,

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which may require travel to Florida to provide assistance to his father who suffers from Parkinsonian

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Syndrome. This request is made in good faith with no intention to unduly delay the proceedings.

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Counsel for Defendant conferred with Plaintiff’s counsel, Cyrus Safa by email on August 14,
2017, who has no opposition to this motion.
Respectfully submitted this 14th day of August 2017.

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STEVEN W. MYHRE, NVBN 9635
United States Attorney
/s/ Richard M. Rodriguez
RICHARRD M. RODRIGUEZ
Special Assistant United States Attorney

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE
DATED:

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8-14-2017

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CERTIFICATE OF SERVICE
I, Richard M. Rodriguez, 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:

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CM/ECF:

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Cyrus Safa, Esq.
Law Offices Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
[e-mail]

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Gerald M. Welt, Esq.
732 S. Sixth Street, Suite 200-D
Las Vegas, NV 89101
[e-mail]

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Dated this 14th day of August, 2017

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/s/ Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney

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