Asberger v. Colvin

Filing 19

ORDER Granting Defendant's 18 Unopposed Motion to Extend Time to file a Cross-Motion to Affirm. Motions due by 4/1/2015. Signed by Magistrate Judge Peggy A. Leen on 3/5/2015. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:14-cv-01209-RFB-PAL Document 18 Filed 02/26/15 Page 1 of 3

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DANIEL G. BOGDEN, NVBN 2137
United States Attorney
District of Nevada
LYNN M. HARADA, CSBN 267616
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CHARLES ASBERGER,

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Plaintiff,

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v.

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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.
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)
) Case No. 1:14-cv-01209-RFB-PAL
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UNOPPOSED MOTION FOR
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EXTENSION OF TIME
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(FIRST REQUEST)
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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security (“Defendant”)

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respectfully requests that the Court extend the time for Defendant to file her Cross-Motion to Affirm by

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30 days from March 2, 2015, to and including April 1, 2015.

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Defendant respectfully requests this extension due to a heavy workload, including several other
district court cases, despite due diligence. Defendant therefore needs additional time to properly address
the issues Plaintiff raises in his Motion for Reversal and/or Remand. This request is made in good faith

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with no intention to unduly delay the proceedings.
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Case 2:14-cv-01209-RFB-PAL Document 18 Filed 02/26/15 Page 2 of 3

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On February 26, 2015, Counsel for Defendant conferred with Plaintiff’s counsel who had no
objection to this motion.
Respectfully submitted this 26th day of February 2015.

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DANIEL G. BOGDEN
United States Attorney

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/s/ Lynn M. Harada
LYNN M. HARADA
Special Assistant United States Attorney

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OF COUNSEL:
DONNA L. CALVERT
Regional Chief Counsel, Region IX

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED:

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March 5, 2015

Case 2:14-cv-01209-RFB-PAL Document 18 Filed 02/26/15 Page 3 of 3

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CERTIFICATE OF SERVICE
I, LYNN M. HARADA, certify that the following individual was served with a copy of the
UNOPPOSED MOTION FOR EXTENSION OF TIME on the date and via the method of service
identified below:

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CM/ECF:

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Marc V. Kalagian
Rohlfing & Kalagian, LLP
211 E. Ocean Blvd., Suite 420
Long Beach, CA 90802
[e-mail]

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Dated this 26th day of February 2015.

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/s/ Lynn M. Harada
LYNN M. HARADA
Special Assistant United States Attorney

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