Isaharov v. Berryhill

Filing 18

ORDER Granting 17 Motion to Extend Time Re: 15 Motion to Remand to Agency. Responses due by 1/22/2018. Signed by Magistrate Judge George Foley, Jr on 12/19/2017. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01958-APG-GWF Document 17 Filed 12/18/17 Page 1 of 3

1 STEVEN W. MYHRE
Acting United States Attorney
2 District of Nevada
3 SHEA LITA BOND, SBN D.C. 469103
Special Assistant United States Attorney
4
160 Spear Street, Suite 800
San Francisco, CA 94105
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Tel: [phone]
Fax: [phone]
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Email: [e-mail]
7 Attorneys for Defendant
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TANYA L. ISAHAROV,

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Plaintiff,

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v.

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

)
) Case No.: 2:17-cv-01958-APG-GWF
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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)

19 respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm
20 in response to Plaintiff’s Motion for Remand (Dkt. No. 15, filed on November 22, 2017), currently due
21 on December 22, 2017, by 31 days, through and including Monday, January 22, 2018. Defendant
22 further requests that all subsequent deadlines set forth in the Court’s Order Concerning Review of
23 Social Security Cases (Dkt. No. 13) be extended accordingly.
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This is Defendant’s first request for an extension of time to respond to Plaintiff’s Motion for

25 Remand. Defendant requests this extension because of the workload of Defendant’s attorney assigned
26 to this case and to allow sufficient time to adequately research and prepare the issues presented by

Case 2:17-cv-01958-APG-GWF Document 17 Filed 12/18/17 Page 2 of 3

1 Plaintiff in her motion. This request is made in good faith and with no intention to unduly delay the
2 proceedings.
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Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this

4 motion, on December 18, 2017.
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It is therefore respectfully requested that Defendant be granted an extension of time to respond

6 to Plaintiff’s Motion for Remand, through and including January 22, 2018.
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Dated: December 18, 2017

Respectfully submitted,

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STEVEN W. MYHRE
Acting United States Attorney

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/s/ Shea Lita Bond
SHEA LITA BOND
Special Assistant United States Attorney

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13 OF COUNSEL:
14 ALLISON J. CHEUNG
Assistant Regional Counsel, Region IX
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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED: ___________________________
12/19/2017

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