Salvati-Bryant v. Berryhill

Filing 15

ORDER granting 14 Motion for Final Enlargement of the Briefing Schedule. Motions due by 11/20/2017. Signed by Magistrate Judge Carl W. Hoffman on 11/16/2017. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-01406-JAD-CWH Document 14 Filed 11/15/17 Page 1 of 2

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HEATHER FREEMAN
Attorney for Plaintiff
IL Bar No. 6282430 / FL Bar No. 40561
Law Office of Heather Freeman, PLLC
P.O. Box 13962
Tallahassee, FL 32308
[phone] / [phone] fax
[e-mail]
Attorney for Plaintiff, Susanne Salvati-Bryant
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
SUSANNE SALVATI-BRYANT,
)
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Case No. 2:17-cv-01406-JAD-CWH
Plaintiff,
)
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v.
)
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NANCY A. BERRYHILL,
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CONSENT MOTION FOR
Acting Commissioner of Social Security,
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FINAL ENLARGEMENT OF THE
)
BRIEFING SCHEDULE
Defendant.
)
____________________________________)

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PLAINTIFF, SUSANNE SALVATI-BRYANT, (“Plaintiff”), by her attorney, Heather

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Freeman, moves this Honorable Court to grant her unopposed motion for a final enlargement of

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the briefing schedule through November 20, 2017, in order to file cross-motions to reverse or

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remand and to affirm the Commissioner’s decision. In support of this Motion, Plaintiff states as

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follows:

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Pursuant to this Court’s Order on Plaintiff’s prior motion, (doc. 11), the cross-motions are

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due on November 15, 2017. This additional and final five day extension is being requested due

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to unforeseen weather related damage and the need to arrange for emergency repairs, which has

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affected counsel’s schedule. In sum, undersigned counsel lives in NH, where a significant wind

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and rain storm caused power and internet outages through Saturday, Nov. 4, with a flash flood

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washing out a significant portion of the only access road. While repairs were being coordinated,

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Case 2:17-cv-01406-JAD-CWH Document 14 Filed 11/15/17 Page 2 of 2

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additional weather yesterday has washed out even more of the road, resulting in a critical
condition that must be immediately addressed (there is no manner of driving around the growing
sinkhole, this is the only access to the house, and it must be repaired before heavy snow starts or
fuel deliveries are needed). With this complication, counsel has been unable to recover the time
lost earlier this month, resulting in scheduling complications. No further extensions will be
requested.
Counsel for the Commissioner has no objection to this Motion.
WHEREFORE, Plaintiff respectfully requests that this consent Motion be granted,
allowing an enlargement of the briefing schedule through November 20, 2017, in order to file
cross-motions to reverse or remand and to affirm the Commissioner’s decision.

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Date: November 15, 2017

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Respectfully submitted,
/s/Heather Freeman__________
HEATHER FREEMAN
Attorney for Plaintiff

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11/16/17

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