Williams v. Nancy A. Berryhill

Filing 20

ORDER Granting 19 Motion to Extend Time to Respond re 15 Motion to Remand to Agency. Responses due by 10/18/2017. Signed by Magistrate Judge Cam Ferenbach on 9/22/17. (Copies have been distributed pursuant to the NEF - MMM)

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STEVEN W. MYHRE
Acting United States Attorney
Nevada State Bar No. 9635
ASIM H. MODI
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [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-1036-JAD-VCF
UNOPPOSED MOTION FOR
EXTENSION OF TIME
(SECOND REQUEST)

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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (“Defendant”)
respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm and
Response to Plaintiff’s Motion for Reversal, due on September 18, 2017, by 30 days, through and
including October 18, 2017. This request is made in good faith with no intention to unduly delay the
proceedings.
An extension of time is needed because this case was recently reassigned to the undersigned
agency counsel, whose existing work commitments preclude him from adequately researching the

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factual and legal issues in the instant case prior to September 18, 2017. In particular, on September 11

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and 12, 2017, the undersigned agency counsel participated in last-minute, work-related travel to present

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oral arguments in a case before the Central District of California and conduct a training presentation for

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the agency’s Downtown Los Angeles Office of Disability Adjudication and Review. Moreover, the

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undersigned agency counsel is currently responsible for performing a range of tasks concurrent with

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drafting the Commissioner’s brief in the instant case, including: drafting briefs and summary judgment

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motions and negotiating (or litigating) attorney fees in cases before federal district courts; drafting the

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Commissioner’s answering brief in a Social Security case before the Ninth Circuit; preparing for a

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hearing in personnel-related litigation pending before the Merit Systems Protection Board; overseeing

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ongoing discovery in personnel-related litigation before the Equal Employment Opportunity

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Commission; assisting with nationally implementing the terms of a class action settlement where the

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agency was a party; and preparing training materials and conducting presentations for the agency’s

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Office of Disability Adjudication and Review.

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

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STEVEN W. MYHRE
Acting United States Attorney

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/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney

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OF COUNSEL:

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DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX

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IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
September 22, 2017
DATED:

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CERTIFICATE OF SERVICE
I, Asim H. Modi, certify that the following individuals were served with the foregoing
UNOPPOSED MOTION FOR EXTENSION (SECOND REQUEST) on the date and via the
method of service identified below:
CM/ECF:
Gerald M. Welt
Gerald M. Welt, Chtd.
732 S. Sixth Street, Suite 200-D
Las Vegas, Nevada 89101
[e-mail]
Cyrus Safa, Esq.
Law Offices of Lawrence D. Rohlfing
12631 E. Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
[e-mail]

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Dated this 14th day of September 2017.

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//s// Asim H, Modi
ASIM H. MODI
Special Assistant United States Attorney

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