Mcdonald v. Commissioner of Social Security

Filing 18

ORDER Granting 17 Unopposed Motion for Extension of Time re 13 Motion to Remand to Agency (Second Request). Responses due by 12/20/2017. Replies due by 1/9/2018. Signed by Magistrate Judge Nancy J. Koppe on 11/14/2017. (Copies have been distributed pursuant to the NEF - MR)

Case 2:17-cv-01445-RFB-NJK Document 17 Filed 11/13/17 Page 1 of 3

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STEVEN W. MYHRE, CSBN 9635
Acting United States Attorney
BLAINE T. WELSH
Chief, Civil Division
GINA TOMASELLI, CSBN 267090
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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MIA ANNE MCDONALD,

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Plaintiff,

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vs.

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

CIVIL NO. 2:17-cv-01445-RFB-NJK
DEFENDANT’S UNOPPOSED
MOTION FOR EXTENSION OF
TIME

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IT IS HEREBY STIPULATED, by and between Mia Anne McDonald (Plaintiff) and Nancy A.

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Berryhill, Acting Commissioner of Social Security (Defendant), by and through their respective counsel

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of record, that Defendant shall have an extension of time of thirty-five (35) days to deliver her Motion

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for Summary Judgment and in Opposition to Plaintiff’s Motion for Summary Judgment. The current due

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date is November 15, 2017. The new due date will be December 20, 2017. The parties further stipulate

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that all other dates will be extended accordingly, and Plaintiff’s reply will be due to Defendant by
January 9, 2018.
This is the second extension of time requested by Defendant in the above-captioned matter.
Defendant requests this extension because this case was recently transferred to another attorney with a
heavy workload and has not had sufficient time to fully consider the issues in this case. This request is
made in good faith with no intention to unduly delay the proceedings. Counsel for Defendant conferred
Stip. & Prop. Order for Ext.; 17-1445

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Case 2:17-cv-01445-RFB-NJK Document 17 Filed 11/13/17 Page 2 of 3

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with Plaintiff’s counsel, who has no opposition to this motion, on March 20, 2017. It is therefore
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respectfully requested that Defendant be granted a thirty-five (35) day extension of time to respond to
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Plaintiff’s motion, up to and including December 20, 2017.

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Respectfully submitted,
Dated: November 13, 2017

By: /s/ Joshua R. Harris *
JOSHUA R. HARRIS
Richard Harris Law Firm
(*by email authorization on 11/13/17)

Dated: November 13, 2017

STEVEN W. MYHRE
Acting United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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By: /s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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Attorneys for Defendant

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IT IS SO ORDERED:

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__________________________________
THE HONORABLE NANCY J. KOPPE
UNITED STATES MAGISTRATE JUDGE

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November 14, 2017
DATE:__________________________

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Stip. & Prop. Order for Ext.; 17-1445

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