Johnson v. Social Security

Filing 16

ORDER granting 14 Motion to Extend Time to File Plaintiff's Opening Brief. Opening brief due by 11/21/2024. Signed by Magistrate Judge Elayna J. Youchah on 11/21/2024. (Copies have been distributed pursuant to the NEF - MAM)

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Hal Taylor, Esq.
Of Counsel, Olinsky Law Group
NV Bar No.: 4399
2551 West Lakeridge Shores
Reno, NV 89519
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Destiny Williams, Esq.
Admitted Pro Hac Vice
NC Bar No.: 54381
250 S. Clinton Street, Suite 210
Syracuse, NY 13202
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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Plaintiff,
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v.
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MARTIN O’MALLEY,
COMMISSIONER OF SOCIAL SECURITY, )
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Defendant.
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__________________________________
TAMMI J. JOHNSON,

CASE NO.
2:24-cv-01156-EJY
UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE
PLAINTIFF’S OPENING BRIEF
NUNC PRO TUNC

PLEASE TAKE NOTICE that Plaintiff, Tammi J. Johnson, by her attorneys, Olinsky
Law Group, Hal Taylor, Esq. and Destiny Williams, Esq., will move and hereby does move this

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Court, for an extension of time to Plaintiff’s Opening Brief, nunc pro tunc. Plaintiff’s Brief was

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due Wednesday, November 20, 2024. Counsel seeks a one (1) day extension of time, or up to

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and including Thursday, November 21, 2024, in which to file the Opening Brief. This request

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will not cause Defendant any undue hardship, and Plaintiff's counsel has conferred with

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Defendant's counsel, who has no objection. This is the first such request submitted by Plaintiff in
this matter.
Counsel requests this extension due to technical difficulties with Attorney Williams’

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Pacer Account. Counsel attempted to file this brief on November 20, 2024; however, she

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received an error message, and her account remained inactive until 7:26AM EST on November

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21, 2024. Therefore, Counsel is seeking a short extension to submit the Opening Brief now that

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her account is operating properly. Counsel apologizes profusely for this any resulting delay and

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will file Plaintiff's Opening Brief immediate after filing this Motion.
The undersigned thus respectfully requests the relief requested in the proposed order filed

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with the Court this day.

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Dated November 21, 2024.

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Respectfully submitted,

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/s/ Destiny Williams
Destiny Williams, Esq.
Admitted Pro Hac Vice
NC Bar No.: 54381
250 S. Clinton Street, Suite 210
Syracuse, NY 13202
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff

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/s/Hal Taylor
Hal Taylor, Esq.
Of Counsel, Olinsky Law Group
NV Bar No.: 4399
2551 West Lakeridge Shores
Reno, NV 89519
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff

IT IS SO ORDERED this 21st day of November, 2024.

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_______________________________________________
ElLAYNA J. YOUCHAH
UNITED STATES MAGISTRATE JUDGE

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