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Strassner v. Berryhill, 2:18-cv-01500-APG-NJK. (2019)

Court: District Court, D. Nevada Number: infdco20190225b08 Visitors: 5
Filed: Feb. 22, 2019
Latest Update: Feb. 22, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND (First Request) NANCY J. KOPPE , 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 February 21, 2019 to April 12, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request f
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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND

(First Request)

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 February 21, 2019 to April 12, 2019. This is Defendant's first request for extension. Good cause exists to grant Defendant's request for extension. Counsel was out of the office on bereavement leave to attend funeral and prayer services following the death of her aunt. In addition, Counsel has over 80+ active social security matters that require two or more dispositive motions per week until mid-April. For example, at this time, Counsel has over 18 dispositive motions due in the month of March. As such, 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 had ongoing health and personal family issues and filed an extension of time as soon as reasonably practicable. The parties further stipulate that the Court's Scheduling Order shall be modified accordingly.

ORDER

APPROVED AND SO ORDERED.

Source:  Leagle

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