Szelap v. Colvin

Filing 22

ORDER Granting 21 Unopposed Motion for Extension of Time re 20 Motion to Remand to Agency. Responses due by 9/18/2015. Signed by Magistrate Judge Nancy J. Koppe on 8/19/15. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-00190-RFB-NJK Document 21 Filed 08/18/15 Page 1 of 3

1 DANIEL G. BOGDEN
United States Attorney
2 District of Nevada
Nevada Bar No. 2137
3 MARLA K. LETELLIER
Special Assistant United States Attorney
4 California Bar No. 234969
160 Spear Street, Suite 800
5 San Francisco, CA 94105
Tel: [phone]
6 Fax: [phone]
Email: [e-mail]
7 Attorneys for Defendant
8
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

9
10
DEANNE SZELAP,
11
Plaintiff,
12
v.
13
14
15
16
17
18
19
20
21
22
23
24
25
26

CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

)
)
)
)
)
) Case No.: 2:15-cv-00190-RFB-NJK
)
)
)
)
)
)

UNOPPOSED MOTION FOR EXTENSION OF TIME
(First Request by Defendant)
COMES NOW Defendant Carolyn W. Colvin, Acting Commissioner of Social Security
(Defendant), by and through her counsel, Daniel G. Bogden, United States Attorney, and Marla
Letellier, Special Assistant United States Attorney, to request that this Court extend the time to
respond to Plaintiff's Motion for Remand, which was filed on July 20, 2015 by 30 days from August
19, 2015 to September 18, 2015. This is Defendant’s first request for an extension of time to respond
to Plaintiff’s Motion. Counsel for Defendant contacted Plaintiff’s counsel on August 18, 2015, and
Plaintiff does not oppose Defendant’s motion. Defendants’ current deadline is August 19, 2015.
The instant request is not intended to cause delay and is necessary because counsel for
Defendant will be out of the office from August 19, 2015 through August 21, 2015, and because of the

Case 2:15-cv-00190-RFB-NJK Document 21 Filed 08/18/15 Page 2 of 3

1 heavy workload of counsel for Defendant, who is responsible for briefing dispositive motions in six
2 federal district court cases between August 18, 2015 and August 28, 2015.
3

It is therefore respectfully requested that Defendant be granted a thirty (30) day extension of

4 time to respond to Plaintiff's motion, up to and including September 18, 2015.
5

Dated: August 18, 2015.

6

Respectfully submitted

7

DANIEL G. BOGDEN
United States Attorney

8
/s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant United States Attorney

9
10
11 OF COUNSEL:
12 DEBORAH STACHEL
Acting Regional Chief Counsel
13
14
15

IT IS SO ORDERED:

16
17

UNITED STATES MAGISTRATE JUDGE

18

August 19, 2015
DATED: ___________________________

19
20
21
22
23
24
25
26

2