Garcia v. Colvin

Filing 16

ORDER Granting 15 Unopposed Motion to Extend Time to Respond to 14 MOTION to Remand to Social Security Administration. Responses due by 8/5/2015. Signed by Magistrate Judge Carl W. Hoffman on 7/7/15. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-00200-MMD-CWH Document 15 Filed 07/06/15 Page 1 of 3

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DANIEL G. BOGDEN
United States Attorney
District of Nevada
JENNIFER A. KENNEY
Special Assistant United States Attorney
CA State Bar 241625
160 Spear St., Suite 800
San Francisco, CA 94105
Tel: [phone]
Fax: [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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MICHAEL A. GARCIA,

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

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Case No. 2:15-CV-00200-MMD-CWH
UNOPPOSED MOTION TO EXTEND TIME
FOR DEFENDANT TO FILE HER RESPONSE
TO PLAINTIFF’S MOTION FOR REVERSAL
AND/OR REMAND (FIRST REQUEST)

COMES NOW Defendant Carolyn W. Colvin, Acting Commissioner of Social Security

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(Defendant), by and through her counsel, Daniel G. Bogden, United States Attorney, and Blaine T.

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Welsh, Assistant United States Attorney, to request that this Court extend the time to respond to

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Plaintiff’s Motion for Reversal and/or Remand by 30 days, from July 6, 2015 to August 5, 2015. All
further deadlines will be extended accordingly. Counsel for Defendant conferred with Plaintiff’s

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counsel, who has no opposition to this motion, on July 6, 2015.
This is Defendant’s first request for an extension. The additional time is necessary due to the
exceptionally heavy workload of Defendant’s attorney assigned to this case. In particular, Defendant’s

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Case 2:15-cv-00200-MMD-CWH Document 15 Filed 07/06/15 Page 2 of 3

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attorney has five Federal District Court briefs due the same week that the instant brief is due, as well

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as court-ordered deadlines in an employment law matter in litigation before the Equal Employment

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Opportunity Commission. The additional time will allow Defendant to address the issues Plaintiff has

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raised in her Motion for Reversal and/or Remand.
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Respectfully submitted this 6th day of July 2015.

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DANIEL G. BOGDEN
United States Attorney

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/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant United States Attorney

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

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IT IS SO ORDERED:

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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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July 7, 2015
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DATED:

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Case 2:15-cv-00200-MMD-CWH Document 15 Filed 07/06/15 Page 3 of 3

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CERTIFICATE OF SERVICE
I, Jennifer A. Kenney, certify that the following individual was served with a copy of the
foregoing UNOPPOSED MOTION TO EXTEND TIME FOR DEFENDANT TO FILE HER
RESPONSE TO PLAINTIFF’S MOTION FOR REVERSAL AND/OR REMAND (FIRST
REQUEST) on the date and via the method of service identified below:

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CM/ECF:

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Joshua R. Harris
Richard Harris Law Firm
801 South Fourth Street
Las Vegas, NV 89101

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Marc V. Kalagian
Rohlfing & Kalagian, LLP
211 E. Ocean Blvd., Suite 420
Long Beach, CA 90802

Dated this 6th day of July 2015.

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/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant United States Attorney

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