Ruiz v. Berryhill

Filing 18

ORDER granting 17 Motion to Extend Time to Respond re: 15 Motion to Remand to Agency. Responses due by 7/20/2018. Signed by Magistrate Judge Cam Ferenbach on 6/28/2018. (Copies have been distributed pursuant to the NEF - MMM)

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DAYLE ELIESON
United States Attorney
District of Nevada
JENNIFER A. KENNEY, SBN CA 241625
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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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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JAMES STEVEN RUIZ,

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Plaintiff,

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v.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.
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) Case No. 2:17-cv-03036-JAD-VCF
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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”)

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respectfully requests that the Court extend the time for Defendant to file her Response to Plaintiff’s

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Motion for Remand/Reversal, due on June 20, 2018, by 30 days, through and including July 20, 2018.

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Defendant’s counsel was recently reassigned to this case and needs the additional time requested

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to adequately research the issues Plaintiff has presented. This request is made in good faith with no

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intention to unduly delay the proceedings.

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Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this motion,
on June 18, 2018.

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Respectfully submitted this 18th day of June 2018.
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DAYLE ELIESON
United States Attorney

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/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
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
DATED:

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6-28-2018

Case 2:17-cv-03036-JAD-VCF Document 17 Filed 06/18/18 Page 3 of 3

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CERTIFICATE OF SERVICE
I, JENNIFER A. KENNEY, certify that the following individual was served with a copy of the
UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service
identified below:

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CM/ECF:

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Marc V. Kalagian
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802

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Leonard Stone
Shook & Stone, Chtd.
710 South 4th Street
Las Vegas, NV 89101

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Dated this 21st day of December 2015.
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/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant United States Attorney

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