Isaharov v. Berryhill

Filing 20

ORDER Granting 19 Motion to Extend Time Re: 15 Motion to Remand to Agency. Responses due by 2/21/2018. Signed by Magistrate Judge George Foley, Jr on 1/18/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01958-APG-GWF Document 19 Filed 01/17/18 Page 1 of 3

1 DAYLE ELIESON
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.

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)
) 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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(SECOND 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), currently due on January 22, 2018, by 30
21 days, through and including Wednesday, February 21, 2018. Defendant further requests that all
22 subsequent deadlines set forth in the Court’s Order Concerning Review of Social Security Cases (Dkt.
23 No. 13) be extended accordingly.
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This is Defendant’s second 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 19 Filed 01/17/18 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 January 16, 2018.
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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 February 21, 2018.
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Dated: January 17, 2018

Respectfully submitted,

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DAYLE ELIESON
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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01/18/2018
DATED: ___________________________

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