Bubna v. Berryhill

Filing 14

ORDER granting 13 Motion to Extend Time; Re: 12 Motion to Remand to Agency. Responses due by 10/17/2018. Signed by Magistrate Judge Cam Ferenbach on 9/12/2018. (Copies have been distributed pursuant to the NEF - JM)

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DAYLE ELIESON
United States Attorney
District of Nevada

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SHARON LAHEY
California State Bar No. 263027
Assistant Regional Counsel
U.S. Social Security Administration
160 Spear Street, Suite 800
San Francisco, California 94105
Phone: [phone]
Facsimile: [phone]
[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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LAS VEGAS DIVISION
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NANCY A. BERRYHILL, Acting Commissioner of Social Security (“Defendant” or the

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WENDY W. BUBNA,

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Plaintiff,

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vs.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

Case No. 2:18-cv-00677-JCM-VCF
DEFENDANT’S UNOPPOSED
MOTION TO EXTEND TIME
(Second Request)

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“Commissioner”), hereby moves this Honorable Court to grant her unopposed motion for a 30-day

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extension of time to file her response to Wendy W. Bubna’s (“Plaintiff”) Motion to Remand to Social

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Security Administration (the “Motion”) (Docket Number 12). The current deadline is September 17,

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2018 and the new deadline would be October 17, 2018. This is the second extension of time requested

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in the above-captioned matter, and it is the Commissioner’s first request for an extension of time. The

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Commissioner requests this additional time because the above-captioned case is being transferred inter-

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office to another attorney in the agency who will need additional time to adequately consider and

UNOPPOSED MOTION AND PROPOSED ORDER

(Case No. 2:18-cv-00677-JCM-VCF)

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address the issues Plaintiff raises in her Motion. Plaintiff’s counsel has stated that Plaintiff does not
oppose the Commissioner’s request for additional time. The Commissioner further respectfully
requests that the scheduling order be modified accordingly.

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Respectfully submitted,
Dated: September 11, 2018

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DAYLE ELIESON
United States Attorney
By:
/s/ Sharon Lahey
SHARON LAHEY
Assistant Regional Counsel

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ORDER

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Pursuant to Defendant’s motion and the parties’ agreement, IT IS SO ORDERED. Defendant
shall file her response to Plaintiff’s Motion to Remand to Social Security Administration on or before
October 17, 2018. All other deadlines are modified accordingly.

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9-12-2018
Dated:________________________

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_________________________________
HON. CAM FERENBACH
UNITED STATES MAGISTRATE JUDGE

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UNOPPOSED MOTION AND PROPOSED ORDER

(Case No. 2:18-cv-00677-JCM-VCF)

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DAYLE ELIESON
United States Attorney
District of Nevada

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SHARON LAHEY
Assistant Regional Counsel
U.S. Social Security Administration
California State Bar No. 263027
160 Spear Street, Suite 800
San Francisco, California 94105
Phone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LAS VEGAS DIVISION

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WENDY W. BUBNA,
Plaintiff,
vs.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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) (Case No. 2:18-cv-00677-JCM-VCF)
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) CERTIFICATE OF SERVICE
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I, Sharon Lahey, Assistant Regional Counsel, hereby certify that the following individual
was served a copy of the foregoing DEFENDANT’S UNOPPOSED MOTION TO EXTEND TIME
on September 11, 2018 via CM/ECF:
Richard A Harris, Esq.
Richard Harris Law Firm
801 South Fourth Street
Las Vegas, NV 89101
Email: [e-mail]
Dated this 11th day of September, 2018

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Joshua R Harris, Esq.
Richard Harris Law Firm
801 South Fourth Street
Las Vegas, NV 89101
Email: [e-mail]
/s/ Sharon Lahey
SHARON LAHEY
Assistant Regional Counsel

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CERTIFICATE OF SERVICE

(Case No. 2:18-cv-00677-JCM-VCF)