Anderson v. Berryhill

Filing 15

ORDER Granting 14 Stipulation for Extension of Time 13 Motion to Remand to Agency (First Request). Responses due by 12/20/2017. Signed by Magistrate Judge George Foley, Jr on 11/21/2017. (Copies have been distributed pursuant to the NEF - MR)

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STEVEN W. MYHRE (NSBN 9635)
Acting United States Attorney
District of Nevada
TINA NAICKER, CSBN 252766
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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KELLY J. ANDERSON,
Plaintiff,

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

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Case No. 2:17-CV-01177-RFB-GWF
JOINT STIPULATION AND [PROPOSED]
ORDER FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S MOTION FOR
REVERSAL AND/OR REMAND

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that

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the time for responding to Plaintiff’s Motion for Reversal and/or Remand be extended for thirty days

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from November 20, 2017 to December 20, 2017. This is Defendant’s first request for extension.

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Good cause exists to grant Defendant’s request for extension. Counsel for Defendant was on

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unexpected medical leave and became behind on her caseload. Additional time is required as Counsel
for Defendant has over 75 active pending matters, of which require 2+ responses to dispositive
motions per week until early-January. Due to current workload demands and shortened staff, Counsel

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needs additional time to adequately review the transcript and properly respond to Plaintiff’s Motion

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for Summary Judgment. Defendant makes this request in good faith with no intention to unduly delay

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the proceedings. The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,

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Dated: November 20, 2017

/s/ *Daniel Jones
(*as authorized by email on November 20, 2017)
DANIEL JONES
Attorney for Plaintiff

Dated: November 20, 2017

STEVEN W. MYHRE
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
ORDER

APPROVED AND SO ORDERED:

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DATED:_______________________
11/21/2017

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HON. GEORGE FOLEY, JR
UNITED STATES MAGISTRATE JUDGE

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CERTIFICATE OF SERVICE

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I, TINA L. NAICKER, certify that the following individual was served with a copy of the

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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO

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RESPOND TO PLAINTIFF’S MOTION FOR REVERSAL AND/OR REMAND on the date and

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via the method of service identified below:

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CM/ECF:
Daniel S. Jones
Law Offices of Charles E. Binder and Harry J. Binder, LLP
60 East 42 Street
Ste 520
New York, NY 10165
212-667-6801
Email: [e-mail]

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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
775-825-2223
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff

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Respectfully submitted this 20th day of November 2017,

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/s/ Tina L. Naicker
TINA L. NAICKER
Special Assistant United States Attorney

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