Avello v. Colvin

Filing 37

ORDER Granting 36 Motion to Extend Time to Respond to 32 Motion and 34 Motion. Responses due by 3/10/2014. Signed by Magistrate Judge George Foley, Jr on 1/8/2014. (Copies have been distributed pursuant to the NEF - SLR)

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Case 2:13-cv-00504-JAD-GWF Document 36 Filed 01/07/14 Page 1 of 3 1 DANIEL G. BOGDEN United States Attorney 2 District of Nevada BLAINE T. WELSH 3 Assistant United States Attorney Nevada Bar No. 4790 4 U.S. Attorney’s Office 333 Las Vegas Boulevard South, Suite 5000 5 Las Vegas, Nevada 89101 Telephone: 702-388-6336 6 Facsimile: 702-388-6787 Email: blaine.welsh@usdoj.gov 7 Attorneys for the Defendant. 8 9 10 11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13 WILLIAM E. AVELLO, 14 15 Plaintiff, v. 16 CAROLYN W. COLVIN, Acting Commissioner Of Social Security, 17 Defendant. 18 19 ) ) ) ) ) ) ) ) ) ) ) CIVIL NO. 2:13-cv-00504-JAD-GWF DEFENDANT’S UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S MOTION FOR REMAND (FIRST REQUEST) DEFENDANT CAROLYN W. COLVIN, Acting Commissioner of Social Security (Defendant) 20 hereby moves this Honorable Court to grant her unopposed motion for a 60-day extension of time to file 21 her response and/or cross-motion to Plaintiff William E. Avello’s motion for reversal or remand. This is 22 the first extension of time requested by Defendant. Defendant requires this extension of time because 23 the volume of cases assigned to the Social Security Administration Office of General Counsel Assistant 24 Regional Counsel responsible for this case is such that she will not be able to complete the brief in a 25 timely fashion. Defendant will transfer this case to another attorney in the Social Security 26 Administration’s Office of General Counsel. However, the new attorney will need additional time to Case 2:13-cv-00504-JAD-GWF Document 36 Filed 01/07/14 Page 2 of 3 1 adequately assess and address the arguments that Plaintiff has raised in his motion for summary 2 judgment. 3 The current due date for Defendant’s response/cross-motion is January 8, 2014. If this 4 unopposed motion is granted, the new due date will be March 10, 2014. 5 The parties have further agreed that the Court’s Scheduling Order shall be modified accordingly. 6 Dated: January 7, 2014. 7 Respectfully submitted, 8 DANIEL G. BOGDEN United States Attorney 9 /s/ Blaine T. Welsh BLAINE T. WELSH Assistant United States Attorney 10 11 OF COUNSEL: 12 DONNA L. CALVERT Acting Regional Chief Counsel, Region IX 13 Social Security Administration 14 SHARON LAHEY Assistant Regional Counsel 15 Social Security Administration, Region IX 16 17 18 19 IT IS SO ORDERED: 20 ___________________________________ UNITED STATES MAGISTRATE JUDGE 21 January 8, 2014 Dated:________________________ 22 23 24 25 26 2 Case 2:13-cv-00504-JAD-GWF Document 36 Filed 01/07/14 Page 3 of 3 CERTIFICATE OF SERVICE 1 2 I, Blaine T. Welsh, certify that the following individuals were served with a copy of the UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service 3 identified below: 4 CM/ECF: 5 Heather Freeman 55 W. Monroe St., Suite 2440 Chicago IL, 60603 Email: hfreeman@ddbchicago.com 6 7 9 Hal Taylor 223 Marsh Avenue Reno, NV 89509 Email: haltaylorlawyer@gbis.com 10 Dated this 7th day of January 2014. 8 11 /s/ Blaine T. Welsh BLAINE T. WELSH Assistant United States Attorney 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 3

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