Cagliari v. Commissioner of Social Security

Filing 20

ORDER Granting 19 Unopposed Motion to Extend Time re 18 Motion to Remand to Agency (Second Request). Responses due by 10/20/2018. Signed by Magistrate Judge Carl W. Hoffman on 9/5/2018. (Copies have been distributed pursuant to the NEF - MR)

Case 2:18-cv-00130-GMN-CWH Document 19 Filed 08/31/18 Page 1 of 3

1
2

DAYLE ELIESON
United States Attorney
District of Nevada

6

MARGARET BRANICK-ABILLA, CSBN 223600
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

7

Attorneys for Defendant

3
4
5

8
9

UNITED STATES DISTRICT COURT

10
11
12
13
14
15
16

DISTRICT OF NEVADA
PAMELA MARIE CAGLIARI,
Plaintiff,
v.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

17
18
19
20
21
22
23
24
25

)
) Case No. 2:18-cv-00130-GMN-CWH
)
) DEFENDANT’S UNOPPOSED MOTION FOR
) EXTENSION OF TIME (SECOND REQUEST)
)
)
)
)
)
)
)
)

Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (Defendant),
respectfully requests a 45-day extension of time, from August 5, 2018 to October 20, 2018, for
Defendant to respond to Plaintiff’s Motion for Reversal and/or Remand in this case.
This is Defendant’s second request for an extension of time. Defendant’s first extension was in
connection with submitting the certified administrative record. Defendant respectfully submits that
good cause exists for a second extension because Defendant’s counsel was out of the office
unexpectedly and requires additional time to complete her review and analysis of the record and the

26
Motion for Extension of Time
Case No. 2:18-cv-00130-GMN-CWH
-1-

Case 2:18-cv-00130-GMN-CWH Document 19 Filed 08/31/18 Page 2 of 3

1
2
3
4

issues raised in Plaintiff’s motion and to prepare Defendant’s response. Defendant’s counsel also has
a number of other briefs due and is trying diligently to manage competing workload demands. This
request is made in good faith with no intention to unduly delay the proceedings. Plaintiff’s counsel
indicated in an email dated August 31, 2018 that he does not oppose this request for an extension.

5
6
7

Respectfully submitted,
Dated: August 31, 2018

8

DAYLE ELIESON
United States Attorney
By:

9
10
11

OF COUNSEL TO DEFENDANT:

12

/s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant

DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

13
14
15

IT IS SO ORDERED:

16
17
HON. CARL W. HOFFMAN
UNITED STATES MAGISTRATE JUDGE

18
19
20

DATED:

21
22
23
24
25
26
Motion for Extension of Time
Case No. 2:18-cv-00130-GMN-CWH
-2-

September 5, 2018

Case 2:18-cv-00130-GMN-CWH Document 19 Filed 08/31/18 Page 3 of 3

1
2
3

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 (SECOND
REQUEST) on the date and via the method of service identified below:

4
5

CM/ECF:

6

Cyrus Safa
Email: [e-mail]
Attorney for Plaintiff

7
8
9
10
11

Gerald Welt
Email: [e-mail]
Attorney for Plaintiff
Date: August 31, 2018
/s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Motion for Extension of Time
Case No. 2:18-cv-00130-GMN-CWH

-3-