Shannon v. Berryhill

Filing 6

ORDER Granting 5 Motion to Extend Time to Answer/Respond re: 1 Complaint. Nancy Berryhill answer due 2/9/2018. Signed by Magistrate Judge Cam Ferenbach on 12/21/2017. (Copies have been distributed pursuant to the NEF - MMM)

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STEVEN W. MYHRE
Acting United States Attorney
Nevada State Bar No. 9635
ASIM H. MODI
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
PATRICIA J. SHANNON,
Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case No. 2:17-cv-1941-JAD-VCF
UNOPPOSED MOTION FOR
EXTENSION OF TIME
(FIRST REQUEST)

Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)
respectfully requests that the Court extend the time for Defendant to respond to Plaintiff’s Complaint,
due on December 26, 2017, by 45 days, through and including February 9, 2018. This request is made
in good faith with no intention to unduly delay the proceedings.
An extension of time is needed because the parties are currently trying to resolve the threshold
question of whether this Court has jurisdiction over Plaintiff’s Complaint. The parties are also relatedly
investigating the status of any pending requests for administrative review of the administrative law

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judge’s decision underlying Plaintiff’s Complaint. The additional time sought in the instant motion

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should allow the parties to resolve the above issues after accounting for anticipated delays caused by the

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upcoming holidays.

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Counsel for Defendant conferred with Plaintiff’s counsel, Richard E. Donaldson, by telephone

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on December 19, 2017. During this telephonic conversation, Plaintiff’s counsel expressed his consent to

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this motion.

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Respectfully submitted this 19th day of December 2017.

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STEVEN W. MYHRE
Acting United States Attorney

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/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney

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OF COUNSEL:

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DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE
12-21-2017
DATED:

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CERTIFICATE OF SERVICE
I, Asim H. Modi, certify that the following individuals were served with the foregoing
UNOPPOSED MOTION FOR EXTENSION (FIRST REQUEST) on the date and via the method of
service identified below:
CM/ECF:
Richard E. Donaldson, Esq.
Richard E. Donaldson, Esq., Chtd.
2300 West Sahara Avenue, Suite 800
Las Vegas, Nevada 89102
[e-mail]
Dated this 19th day of December 2017.

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//s// Asim H, Modi
ASIM H. MODI
Special Assistant United States Attorney

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