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)
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
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Attorneys for the Defendant.
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
13 WILLIAM E. AVELLO,
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Plaintiff,
v.
16 CAROLYN W. COLVIN, Acting Commissioner
Of Social Security,
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Defendant.
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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.
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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.
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The parties have further agreed that the Court’s Scheduling Order shall be modified accordingly.
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Dated: January 7, 2014.
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Respectfully submitted,
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DANIEL G. BOGDEN
United States Attorney
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/s/ Blaine T. Welsh
BLAINE T. WELSH
Assistant United States Attorney
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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
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IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
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January 8, 2014
Dated:________________________
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Case 2:13-cv-00504-JAD-GWF Document 36 Filed 01/07/14 Page 3 of 3
CERTIFICATE OF SERVICE
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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:
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CM/ECF:
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Heather Freeman
55 W. Monroe St., Suite 2440
Chicago IL, 60603
Email: hfreeman@ddbchicago.com
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Hal Taylor
223 Marsh Avenue
Reno, NV 89509
Email: haltaylorlawyer@gbis.com
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Dated this 7th day of January 2014.
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/s/ Blaine T. Welsh
BLAINE T. WELSH
Assistant United States Attorney
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