Bortolamedi v. Berryhill

Filing 17

ORDER Granting 16 Motion to Extend Time. Motions due by 1/29/2018. Signed by Magistrate Judge Peggy A. Leen on 1/4/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01473-JAD-PAL Document 16 Filed 12/27/17 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
)
(SECOND 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 December 28, 2017, by 30 days,

22

through and including January 29, 2018. 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 16 Filed 12/27/17 Page 2 of 3

1

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

2

December 2017 and January 2018, including four other district court cases that require imminent

3

briefing by January 5, 2018 and four personnel-related litigation pending before the Equal Employment

4

Opportunity Commission that require completion of deposition and written discovery by February 2,

5

2018. This request is made in good faith with no intention to unduly delay the proceedings.

6
7
8
9
10
11
12

Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion,
on December 27, 2017.
Respectfully submitted, December 27, 2017.
STEVEN W. MYHRE
Acting United States Attorney
/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney

13
14

IT IS SO ORDERED:

15
16

UNITED STATES MAGISTRATE JUDGE

17

DATED: January 4, 2018

18
19
20
21
22
23
24
25
26

-2-

Case 2:17-cv-01473-JAD-PAL Document 16 Filed 12/27/17 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 (Second Request) 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: December 27, 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-