Lowe v. Berryhill
Filing
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ORDER Granting 14 Motion to Extend Time (First Request) Re: 6 Complaint. Defendant's answer and time to submit the certified administrative record is extended to 1/17/2018. Signed by Magistrate Judge Cam Ferenbach on 12/15/2017. (Copies have been distributed pursuant to the NEF - SLD)
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STEVEN W. MYHRE
Acting United States Attorney
District of Nevada
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MARGARET BRANICK-ABILLA, CSBN 223600
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 977-8929
Facsimile: (415) 744-0134
E-Mail: Margaret.Branick-Abilla@ssa.gov
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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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BOBBIE LOWE
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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-02619-GMN-VCF
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) DEFENDANT’S UNOPPOSED MOTION FOR
) EXTENSION OF TIME (FIRST REQUEST)
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Motion for Extension of Time
Case No. 2:17-cv-02619-GMN-VCF
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)
respectfully requests a 30-day extension of time, from December 18, 2017 to January 17, 2018 for
Defendant to answer the complaint and submit the certified administrative record (CAR) in the abovecaptioned case.
This is Defendant’s first request for an extension of time. Defendant respectfully submits that
the requested extension is necessary to allow the Commissioner to prepare the CAR for submission to
this Court and parties in this action. It has taken longer than anticipated to prepare the CAR despite
the Commissioner’s diligent efforts to have it ready in time. This request is made in good faith with
no intention to unduly delay the proceedings.
Counsel for Defendant conferred via email with Plaintiff’s counsel, who indicated on
December 14, 2017 that Plaintiff does not oppose this motion or the requested extension.
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Respectfully submitted,
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Dated: December 14, 2017
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STEVEN W. MYHRE
Acting United States Attorney
By:
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OF COUNSEL TO DEFENDANT:
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/s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
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IT IS SO ORDERED:
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HON. CAM FERENBACH
UNITED STATES MAGISTRATE JUDGE
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DATED:
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Motion for Extension of Time
Case No. 2:17-cv-02619-GMN-VCF
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12-15-2017
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CERTIFICATE OF SERVICE
I, Margaret Branick-Abilla, certify that the following individual(s) was served with a copy of
the DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST
REQUEST) on the date and via the method of service identified below:
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CM/ECF:
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Hannalore Burns Merritt
Email: hannalore@mydisabilityattorney.com
Attorney for Plaintiff
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Hal Taylor
Email: haltaylorlawyer@gbis.com
Attorney for Plaintiff
Date: December 14, 2017
/s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
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Motion for Extension of Time
Case No. 2:17-cv-02619-GMN-VCF
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