Mandell v. Astrue

Filing 20

ORDER Granting 19 Unopposed Motion to Extend Time to Respond to 18 MOTION to Remand to Social Security filed by Eve T. Mandell. Response due by 8/16/2013. Signed by Magistrate Judge Peggy A. Leen on 7/22/13. (Copies have been distributed pursuant to the NEF - EDS)

Case 2:13-cv-00012-GMN-PAL Document 19 Filed 07/17/13 Page 1 of 3

1 DANIEL G. BOGDEN

United States Attorney

2 District of Nevada

Nevada Bar No. 2137

3 CARLOS A. GONZALEZ

Assistant United States Attorney

4 333 South Las Vegas Blvd. Suite 5000

Las Vegas, NV 89101

5 Tel: [phone]

Fax: [phone]

6 Email: [e-mail]

Attorneys for Defendant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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EVE T. MANDELL,

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Plaintiff,

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v.

CAROLYN W. COLVIN,
Acting Commissioner of Social
14 Security,
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Defendant.

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UNOPPOSED MOTION FOR EXTENSION OF TIME
(First Request)

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COMES NOW Defendant Carolyn W. Colvin, Acting Commissioner of Social Security

19 (Defendant), by and through her counsel, Daniel G. Bogden, United States Attorney, and Carlos A.
20 Gonzalez, Assistant United States Attorney, to request that this Court extend the time to respond to
21 Plaintiff's Motion for Reversal and/or Remand. This is Defendant's first request for an extension of
22 time. Plaintiff’s counsel was contacted on July 16, 2013, and Plaintiff does not oppose Defendant's
23 motion. Defendants’ current deadline is July 17, 2013.
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The instant request is not intended to cause delay and is necessary because Defendant needs

25 additional time to consider the issue involved in this case and because of the heavy workload of
26 Defendant's attorney assigned to this case. Defendant's counsel has completed a draft of Defendant's

Case 2:13-cv-00012-GMN-PAL Document 19 Filed 07/17/13 Page 2 of 3

1 Cross-Motion to Affirm; however, Defendant needs additional time to complete the internal agency
2 review process. In addition, counsel assigned to this case has three additional District Court briefs due
3 within a week of the deadline in this case, in addition to other agency matters.
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It is therefore respectfully requested that Defendant be granted a thirty (30) day extension of

5 time to respond to Plaintiff's motion, up to and including August 16, 2013.
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Dated: July 17, 2013.

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Respectfully submitted

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DANIEL G. BOGDEN
United States Attorney

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/s/ Carlos A. Gonzalez
CARLOS A. GONZALEZ
Assistant United States Attorney

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12 OF COUNSEL:
13 DONNA L. CALVERT
Acting Regional Chief Counsel
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ELLINOR R. CODER
15 Assistant Regional Counsel
Social Security Administration
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IT IS SO ORDERED:
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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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July 22, 2013
DATED: ___________________________

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Case 2:13-cv-00012-GMN-PAL Document 19 Filed 07/17/13 Page 3 of 3

CERTIFICATE OF SERVICE

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I, Carlos A. Gonzalez, certify that the following individual(s) were served with a copy of the

3 foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME on the date, and via the method
4 of service, identified below:
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CM/ECF:
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Marc V. Kalagian, Esq.
Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802
Email: [e-mail]

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Dated this 17th day of July, 2013

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/s/ Carlos A. Gonzalez
CARLOS A. GONZALEZ
Assistant United States Attorney

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