Thacker v. Colvin

Filing 16

ORDER that 14 Motion to Extend Time to Answer/Respond re 5 Amended Complaint is GRANTED. Carolyn W. Colvin answer due 1/18/2016. Signed by Magistrate Judge Peggy A. Leen on 12/4/15. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:15-cv-00466-RCJ-PAL Document 14 Filed 12/03/15 Page 1 of 3

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DANIEL G. BOGDEN
United States Attorney
District of Nevada
TOVA D. WOLKING, CSBN 259782
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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KAREN D. THACKER,

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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. 15-cv-00466 RCJ-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 by forty-five (45) days, to January 18, 2016, for

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Defendant to file her Answer to the Complaint. It is currently due on December 7, 2015.

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An extension of time is needed to file Defendant’s Answer because the Office of Disability

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Adjudication and Review (ODAR) requires additional time to prepare and produce the certified

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administrative record in this case. Additionally, Counsel for Defendant has been assigned to another

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Case 2:15-cv-00466-RCJ-PAL Document 14 Filed 12/03/15 Page 2 of 3

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workload and all of her cases are being reassigned. Thus, an extension of time is required to complete

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the reassignment. This request is made in good faith with no intention to unduly delay the proceedings.

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Counsel for Defendant conferred with Plaintiff’s counsel, Marc V. Kalagian, on December 3,
2015. He stated that he would not oppose this motion.
Respectfully submitted this 3rd day of December 2015.

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DANIEL G. BOGDEN
United States Attorney

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/s/ Tova D. Wolking
TOVA D. WOLKING
Special Assistant United States Attorney

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OF COUNSEL:
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE
DATED: December 4, 2015

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Case 2:15-cv-00466-RCJ-PAL Document 14 Filed 12/03/15 Page 3 of 3

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CERTIFICATE OF SERVICE
I, Tova D. Wolking, certify that the following individuals were 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
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, CA 90802

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Leonard Stone
Shook & Stone, Chtd.
710 South 4th Street
Las Vegas, NIV 89101

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Dated this 3rd day of December 2015.
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/s/ Tova D. Wolking
TOVA D. WOLKING
Special Assistant United States Attorney

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