Salvati-Bryant v. Berryhill

Filing 11

ORDER Granting 10 Motion to Extend Briefing Schedule. Motions due by 11/15/2017. Signed by Magistrate Judge Carl W. Hoffman on 9/13/17. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-01406-JAD-CWH Document 10 Filed 09/12/17 Page 1 of 2

HAL TAYLOR
Nevada Bar No. 4399
223 Marsh Ave.
Reno, NV 89509
Tel: [phone]
Fax: [phone]
ha1tay1or1awyergmai1.com
Attorney for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
SUSANNE SALVATI-BRYANT,
)
Case No. 2:17-cv-01406-JAD-CW}J
)
Plaintiff,
)
)
V.
)
)
NANCY A. BERRYHILL,
CONSENT MOTION FOR
)
ENLARGEMENT OF THE
Acting Commissioner of Social Security, )
BRIEFING SCHEDULE
)
Defendant. )
)
PLAINTIFF, SUSANNE SALVATI-BRYANT, ("Plaintiff"), by her attorney, Hal
Taylor, moves this Honorable Court to grant her unopposed motion for a sixty (60) day
enlargement of the briefing schedule through November 15, 2017, in order to file cross-motions
to reverse or remand and to affirm the Commissioner's decision. In support of this Motion,
Plaintiff states as follows:
Pursuant to this Court's Order (doc. 7), the cross-motions are due on
September 16, 2017. This consent motion for an enlargement of the briefing schedule is
submitted due to the lengthy administrative record of 1,877 pages and co-counsel and primary
brief-writing attorney for Plaintiff being unavailable due to previously scheduled matters
between September 26— 29 and October 2— 13, 2017.

Case 2:17-cv-01406-JAD-CWH Document 10 Filed 09/12/17 Page 2 of 2

Counsel for the Commissioner, Assistant Regional Counsel Sundeep R. Patel and
Assistant United States Attorney Mark B. Woolf, were contacted on September 11, 2017, and
informed counsel that there is no objection to this Motion.
WHEREFORE, Plaintiff respectfully requests that this consent Motion be granted,
allowing an enlargement of the briefing schedule through November 15, 2017, in order to file
cross-motions to reverse or remand and to affirm the Commissioner's decision.

Date: September 12, 2017

Respectfully submitted,
Is/Hal Taylor
HAL TAYLOR
Nevada Bar No. 4399
223 Marsh Ave.
Reno, NV 89509
Tel: [phone]
Fax: [phone]
haltay1orlawyergmai1.com
Attorney for Plaintiff

September 13,
2017

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