Asberger v. Colvin

Filing 21

ORDER Granting Defendant's 20 Unopposed Motion to Extend Time (Second Request) to File Cross-Motion to Affirm. Motions due by 5/1/2015. Signed by Magistrate Judge Peggy A. Leen on 4/7/2015. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:14-cv-01209-RFB-PAL Document 20 Filed 04/01/15 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. 2:
1:14-cv-01209-RFB-PAL
)
)
)
UNOPPOSED MOTION FOR
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EXTENSION OF TIME
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(SECOND 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 April 1, 2015, to and including May 1, 2015.

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Defendant respectfully requests this extension due to a heavy workload, including several other

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district court cases, despite due diligence, and because Defendant was out of the office for several days.

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Defendant therefore needs additional time to prepare a response in this matter and properly address the

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Case 2:14-cv-01209-RFB-PAL Document 20 Filed 04/01/15 Page 2 of 3

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issues Plaintiff raises in his motion. This request is made in good faith with no intention to unduly delay

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the proceedings. This is Defendant’s second request for an extension.

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On April 1, 2015, Counsel for Defendant conferred with Plaintiff’s counsel who had no objection
to this motion.
Defendant sincerely apologizes to the Court for any inconvenience caused by this delay.
Respectfully submitted this 1st day of April 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:

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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: April 7, 2015

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Case 2:14-cv-01209-RFB-PAL Document 20 Filed 04/01/15 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 (SECOND REQUEST) 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 1st day of April 2015.

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

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