Tea Cisneros-Dysthe v. Berryhill, et al

Filing 16

ORDER Granting 15 Motion to Extend Time. Motions due by 1/26/2018. Signed by Magistrate Judge George Foley, Jr on 12/27/2017. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-02143-RFB-GWF Document 15 Filed 12/26/17 Page 1 of 2

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RICHARD A. HARRIS, ESQ.
Nevada State Bar No. 505
JOSHUA R. HARRIS, ESQ.
Nevada State Bar No. 9580
RICHARD HARRIS LAW FIRM
801 S FOURTH ST.
LAS VEGAS NV 89101
Ph: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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TEA CISNEROS-DYSTHE,

Case No. 2:17-cv-02143-RFB-GWF

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Plaintiff,

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vs.

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COMMISSIONER OF SOCIAL
SECURITY,

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PLAINTIFF’S UNOPPOSED
MOTION FOR EXTENSION OF
TIME TO FILE MOTION FOR
REMAND AND/OR REVERSAL
(FIRST REQUEST)

Defendant.

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IT IS HEREBY STIPULATED, by and between TEA CISNEROS-DYSTHE (Plaintiff)
and NANCY A. BERRYHILL, Acting Commissioner of Social Security (Defendant), by and
through their respective counsel of record, that Plaintiff shall have an extension of time to
deliver the MOTION FOR REMAND AND/OR REVERSAL.

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The current due date is December 27, 2017. The new due date will be January 26, 2018.

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The parties further stipulate that all other dates will be extended accordingly, and Defendant’s

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response will be due to Plaintiff by February 25, 2018.

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This is the first extension of time requested by Plaintiff in the above-captioned matter.
Plaintiff requests this extension because the Appellate Attorney Writer is ill to the extent her
vision is affected and she therefore cannot effectively write. This request is made in good faith

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with no intention to unduly delay the proceedings. Counsel for Plaintiff has conferred with
Defendant’s counsel, who had no opposition to this motion on December 26, 2017.

Case 2:17-cv-02143-RFB-GWF Document 15 Filed 12/26/17 Page 2 of 2

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It is therefore respectfully requested that Plaintiff be granted a thirty (30) day

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extension of time to file the MOTION FOR REMAND AND/OR REVERSAL up to

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and including January 26, 2018.

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DATED this 26th day of December 2017.

DATED this 26th day of December 2017.

/s/ Richard A. Harris
RICHARD A. HARRIS, ESQ.
Nevada State Bar No. 505
RICHARD HARRIS LAW FIRM
801 S FOURTH ST.
LAS VEGAS NV 89101
Ph: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff

/s/ Richard M. Rodriguez
(As authorized via email 12/26/17 10:02am)
MARK E WOOLF
United States Attorney
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
Attorneys for Defendant

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IT IS SO ORDERED.

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___________________________________
THE HONORABLE GEORGE FOLEY, JR.
UNITED STATES MAGISTRATE JUDGE

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December 27, 2017
DATE: ____________________________