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`Hal Taylor, Esq.
`Of Counsel, Olinsky Law Group
`NV Bar No.: 4399
`2551 West Lakeridge Shores
`Reno, NV 89519
`Tel: (775) 825-2223
`Fax: (775) 329-1113
`Email: HalTaylorLawyer@gbis.com
`Attorney for Plaintiff
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`LADONNA MARIE RATHEL,
`
`Plaintiff,
`
`v.
`
`KILOLO KIJAKAZI, ACTING
`COMMISSIONER OF SOCIAL SECURITY,
`
`Defendant.
`__________________________________
`
`)
`)
`) CASE NO.
`
`) 3:23-cv-00144-LRH-CSD
`
`)
`) UNOPPOSED MOTION
`
`) FOR EXTENSION OF TIME TO FILE
`) PLAINTIFF’S BRIEF
`)
`)
`)
`)
`
`Plaintiff, Ladonna Marie Rathel, by her attorney, moves for a sixty (60) day extension of
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`time to file Plaintiff’s opening brief. Plaintiff’s opening brief is currently due to be filed July 20,
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`2023.
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`Counsel requests this extension due to multiple, simultaneous filing deadlines. Counsel
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`requires additional time to properly and thoroughly prepare Plaintiff’s brief. For instance,
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`between July 14, and September 14, 2023, staff in Counsel’s office have two hundred and thirty-
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`nine (239) Plaintiff briefs due. This figure does not include Oral Arguments, appeals to Circuit
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`Courts, Reply Briefs, settlement negotiations, and the various other tasks which arise throughout
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`the course of litigation. These circumstances do not allow for Plaintiff’s Counsel to properly
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`prepare the brief by the current deadline. This request will not cause Defendant any undue
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`ORDER GRANTING
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`
`
`Case 3:23-cv-00144-LRH-CSD Document 11 Filed 07/14/23 Page 2 of 2
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`hardship. This extension is needed to thoroughly and properly prepare the brief by the current
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`deadline.
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`Wherefore, Plaintiff requests an extension from July 20, 2023, up to and including
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`September 18, 2023 to file their brief. Counsel for the Plaintiff has conferred with Defendant’s
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`Counsel who kindly has no objection to this request.
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`Dated July 13, 2023.
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`Respectfully submitted,
`
`/s/Hal Taylor
`Hal Taylor, Esq.
`
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`2
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`IT IS SO ORDERED.
`DATED: July 14, 2023.
`
`_____________________________________
`UNITED STATES MAGISTRATE JUDGE
`
`
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