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Durr v. Berryhill, 2:18-cv-01907-APG-BNW. (2019)

Court: District Court, D. Nevada Number: infdco20190515g19 Visitors: 26
Filed: May 14, 2019
Latest Update: May 14, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND BRENDA WEKSLER , Magistrate Judge . IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for Defendant to file her response to Plaintiff's Motion for Reversal/Remand be extended from May 9, 2019 to May 15, 2019. This is Defendant's fourth request for extension. Good cause exists to grant Defendant's request for extension. Since the time o
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND

IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record, that the time for Defendant to file her response to Plaintiff's Motion for Reversal/Remand be extended from May 9, 2019 to May 15, 2019. This is Defendant's fourth request for extension. Good cause exists to grant Defendant's request for extension. Since the time of the last extension, Counsel has been taking care of her elderly mother following the death of Counsel's uncle and two cousins. Counsel's mother is scheduled for surgery and was out of the office on the date of the current filing deadline to take her mother to the hospital. Due to unexpected leave, Counsel respectfully requests additional time to adequately review the transcript and respond to the issues raised in Plaintiff's Motion. Defendant makes this request in good faith with no intention to unduly delay the proceedings. Defendant apologizes for the belated request for extension, but filed an extension of time as soon as reasonably practicable. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

Respectfully submitted, Dated: May 9, 2019 /s/Joshua Harris (*as authorized by email on May 9, 2019) JOSHUA HARRIS Attorney for Plaintiff Dated: May 9, 2019 NICHOLAS A. TRUTANICH United States Attorney DEBORAH LEE STACHEL Regional Chief Counsel, Region IX Social Security Administration By /s/Tina L. Naicker TINA L. NAICKER Special Assistant U.S. Attorney Attorneys for Defendant

ORDER

APPROVED AND SO ORDERED.

Source:  Leagle

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