Anderson v. Berryhill

Filing 17

ORDER granting 16 Stipulation; Re: 13 Motion to Remand to Agency Responses due by 1/17/2018. Signed by Magistrate Judge George Foley, Jr on 12/15/2017. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-01177-RFB-GWF Document 16 Filed 12/14/17 Page 1 of 3

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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 December 20, 2017 to January 17, 2018. This is Defendant’s second request for extension.

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Good cause exists to grant Defendant’s request for extension. Counsel was unexpectedly out sick with

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the flu and became behind on her caseload. Additional time is required as Counsel has over 75 active
pending matters, of which require 2+ responses to dispositive motions per week until mid-January. In
addition, Counsel has three pending Ninth Circuit matters, which require additional levels or review.

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Case 2:17-cv-01177-RFB-GWF Document 16 Filed 12/14/17 Page 2 of 3

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Counsel is also expected to take some time off for the upcoming holidays. Due to current workload

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demands and shortened staff, Counsel needs additional time to adequately review the transcript and

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properly respond to Plaintiff’s Motion for Summary Judgment. Defendant makes this request in good
faith with no intention to unduly delay 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: December 14, 2017

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

Dated: December 14, 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

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ORDER

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APPROVED AND SO ORDERED:

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DATED:_______________________
12/15/2017

_________________________
HON. GEORGE FOLEY, JR
UNITED STATES MAGISTRATE JUDGE

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