Anderson v. Berryhill

Filing 19

ORDER granting 18 Stipulation; Re: 13 Motion to Remand to Agency. Responses due by 1/24/2018. Signed by Magistrate Judge George Foley, Jr on 1/18/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-01177-RFB-GWF Document 18 Filed 01/17/18 Page 1 of 3

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DAYLE ELIESON
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 one week

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from January 17, 2018 to January 24, 2018. This is Defendant’s third request for extension. Good

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cause exists to grant Defendant’s request for extension. Counsel is taking leave, including on the date

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of the current filing deadline due an unanticipated family emergency. 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

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Case 2:17-cv-01177-RFB-GWF Document 18 Filed 01/17/18 Page 2 of 3

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additional levels or review. Counsel apologizes for the belated nature of the request, but did not

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expect to take unanticipated leave due to the family emergency. As such, Counsel respectfully

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requests additional time to adequately review the transcript and 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: January 18, 2018

/s/ *Daniel Jones
(*as authorized by email on January 18, 2018)
DANIEL JONES
Attorney for Plaintiff

Dated: January 18, 2018

DAYLE ELIESON
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

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APPROVED AND SO ORDERED:

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DATED:_______________________
1/18/2018

_________________________
HON. GEORGE FOLEY, JR
UNITED STATES MAGISTRATE JUDGE

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