Beseau v. Colvin

Filing 22

ORDER Granting 21 Motion to Extend Time to Respond to 19 Motion to Remand to Agency. Response due by 7/24/2015. Signed by Magistrate Judge George Foley, Jr on 6/26/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:14-cv-01952-GMN-GWF Document 21 Filed 06/25/15 Page 1 of 3

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DANIEL G. BOGDEN
United States Attorney
Nevada State Bar No. 2137
ASIM H. MODI, NY SBN 4692018
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RUSTY W. BESEAU,

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Plaintiff,

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vs.

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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

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Case No.: 2:14-cv-01952-GMN-GWF
UNOPPOSED MOTION FOR
EXTENSION OF TIME
(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

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Affirm and Response to Plaintiff’s Motion for Reversal, due on June 26, 2015, by 28 days,

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through and including July 24, 2015.
There is good cause for this extension because the case is being transferred to another
attorney in the Commissioner’s office and needs additional time to complete the responsive

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pleading. Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to

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this motion, on June 24, 2015.

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Case 2:14-cv-01952-GMN-GWF Document 21 Filed 06/25/15 Page 2 of 3

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Respectfully submitted this 25th day of June 2015.

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DANIEL G. BOGDEN
United States Attorney

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/s/ Asim H. Modi
ASIM H. MODI
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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GEORGE FOLEY, JR.
UNITED STATES MAGISTRATE JUDGE

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DATED: June 26, 2015

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Case 2:14-cv-01952-GMN-GWF Document 21 Filed 06/25/15 Page 3 of 3

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CERTIFICATE OF SERVICE

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I, Asim H. Modi, certify that the following individual was served with a copy of the
UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST 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, Esq.
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, California 90802
[e-mail]

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Dated this 25th day of June 2015

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//s// Asim H, Modi
ASIM H. MODI
Special Assistant United States Attorney

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