Dutraferea v. Berryhill

Filing 22

ORDER Granting 21 Motion to Extend Time (First Request) Re: 20 Motion to Remand and to File Cross-Motion to Affirm. Defendant's Responses to 20 Motion and Cross-Motion due by 3/17/2018. Signed by Magistrate Judge Peggy A. Leen on 2/15/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-01729-RFB-PAL Document 21 Filed 02/13/18 Page 1 of 3

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DAYLE ELIESON
United States Attorney
District of Nevada

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BEN A. PORTER
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
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DISTRICT OF NEVADA
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JEANNIE DUTRAFEREA,
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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. 2:13-cv2:17-cv-01729-RFB-PAL
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UNOPPOSED MOTION FOR
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EXTENSION OF TIME
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(FIRST REQUEST)
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)
respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm and
Opposition to Plaintiff’s Motion for Reversal, due on February 15, 2018, by 30 days, through and
including March 17, 2018.
An extension of time is needed because Defendant’s counsel has had a high workload volume in
the month of February and needs additional time to prepare Defendant’s opposition brief in this case.

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Case 2:17-cv-01729-RFB-PAL Document 21 Filed 02/13/18 Page 2 of 3

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This is Defendant’s first request for an extension. The motion is made in good faith with no intention to

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unduly delay the proceedings.

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Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion,
on February 13, 2018.
Respectfully submitted this 13th day of February 2018.

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DAYLE ELIESON
United States Attorney

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/s/ Ben A. Porter
BEN A. PORTER
Special Assistant United States Attorney

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OF COUNSEL:
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE
DATED:

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February 15, 2018

Case 2:17-cv-01729-RFB-PAL Document 21 Filed 02/13/18 Page 3 of 3

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CERTIFICATE OF SERVICE
I, Ben A. Porter, certify that the following individual was served with a copy of the

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UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service

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identified below:

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CM/ECF:

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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]

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Dated this 13th day of January 2014.
/s/ Ben A. Porter
BEN A. PORTER
Special Assistant United States Attorney

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