Bortolamedi v. Berryhill

Filing 15

ORDER Granting 14 Motion to Extend Time. Motions due by 12/28/2017. Signed by Magistrate Judge Peggy A. Leen on 11/20/2017. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01473-JAD-PAL Document 14 Filed 11/13/17 Page 1 of 3

1
2
3

STEVEN W. MYHRE
Acting United States Attorney
District of Nevada

6

BEATRICE NA, SBN CA 303390
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

7

Attorneys for Defendant

4
5

8
9
10

UNITED STATES DISTRICT COURT

11

DISTRICT OF NEVADA

12

JACQUELYNN BORTOLAMEDI,

13

Plaintiff,

14

v.

15
16

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

17

)
) Case No. 2:17-cv-01473-JAD-PAL
)
)
)
UNOPPOSED MOTION FOR
)
EXTENSION OF TIME
)
(FIRST REQUEST)
)
)
)
)

18
19

Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)

20

respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm in

21

response to Plaintiff’s Motion for Judgment (Dkt. No. 13) due on November 13, 2017, by 45 days,

22

through and including December 28, 2017. Defendant further requests that all subsequent deadlines set

23

forth in the Court’s Order Concerning Review of Social Security Cases (Dkt. No. 10) shall be extended

24

accordingly.

25

///

26

///

-1-

Case 2:17-cv-01473-JAD-PAL Document 14 Filed 11/13/17 Page 2 of 3

1

Defendant requests this extension because of her attorney’s heavy workload for the months of

2

November and December 2017. This request is made in good faith with no intention to unduly delay the

3

proceedings.

4
5
6
7
8
9
10

Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion,
on November 13, 2017.
Respectfully submitted, November 13, 2017.
STEVEN W. MYHRE
Acting United States Attorney
/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney

11
12

IT IS SO ORDERED:

13
14

UNITED STATES MAGISTRATE JUDGE

15

DATED: November 20, 2017

16
17
18
19
20
21
22
23
24
25
26

-2-

Case 2:17-cv-01473-JAD-PAL Document 14 Filed 11/13/17 Page 3 of 3

1
2
3

CERTIFICATE OF SERVICE
I, BEATRICE NA, certify that the following individual was served with a copy of the
UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service
identified below:

4

CM/ECF:

5

Daniel S. Jones
Law Offices of Charles E. Binder and Harry J. Binder, LLP
485 Madison Ave Suite 501
New York, NY 10022
212-667-6801
Email: [e-mail]

6
7
8

11

Hal Taylor
223 Marsh Avenue
Reno, NV 89509
775-825-2223
Fax: [phone]
Email: [e-mail]

12

Dated: November 13, 2017

9
10

13
14

/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney

15
16
17
18
19
20
21
22
23
24
25
26

-3-