Bortolamedi v. Berryhill
Filing
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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
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STEVEN W. MYHRE
Acting United States Attorney
District of Nevada
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BEATRICE NA, SBN CA 303390
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8967
Facsimile: (415) 744-0134
E-Mail: Beatrice.Na@ssa.gov
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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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JACQUELYNN BORTOLAMEDI,
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Plaintiff,
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v.
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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.
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) Case No. 2:17-cv-01473-JAD-PAL
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UNOPPOSED MOTION FOR
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EXTENSION OF TIME
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(SECOND REQUEST)
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)
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respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm in
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response to Plaintiff’s Motion for Judgment (Dkt. No. 13) due on December 28, 2017, by 30 days,
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through and including January 29, 2018. Defendant further requests that all subsequent deadlines set
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forth in the Court’s Order Concerning Review of Social Security Cases (Dkt. No. 10) shall be extended
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accordingly.
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///
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///
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Case 2:17-cv-01473-JAD-PAL Document 16 Filed 12/27/17 Page 2 of 3
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Defendant requests this extension because of her attorney’s heavy workload for the months of
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December 2017 and January 2018, including four other district court cases that require imminent
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briefing by January 5, 2018 and four personnel-related litigation pending before the Equal Employment
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Opportunity Commission that require completion of deposition and written discovery by February 2,
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2018. This request is made in good faith with no intention to unduly delay the proceedings.
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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
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IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
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DATED: January 4, 2018
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Case 2:17-cv-01473-JAD-PAL Document 16 Filed 12/27/17 Page 3 of 3
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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:
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CM/ECF:
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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: fedcourt@binderlawfirm.com
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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
775-825-2223
Fax: 775-329-1113
Email: haltaylorlawyer@gbis.com
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Dated: December 27, 2017
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/s/ Beatrice Na
BEATRICE NA
Special Assistant United States Attorney
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