Gill v. Colvin

Filing 18

ORDER Granting 16 Motion to Extend Time to file Defendant's Cross-Motion to Affirm (First Request). Cross-Motion to Affirm due 10/13/2015. Signed by Magistrate Judge Carl W. Hoffman on 9/14/15. (Copies have been distributed pursuant to the NEF - PS)

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MARC V. KALAGIAN
Attorney at Law: 4460
211 East Ocean Boulevard, Suite 420
Long Beach, California 90802
Phone: [phone]
Fax: [phone]
[e-mail]

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DANIEL G. BOGDEN, NVBN 2137
United States Attorney
BLAINE T. WELSH
Chief, Civil Division
APRIL A. ALONGI, VABN 76459
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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TAMMY A. GILL,

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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: 2:15-cv-00553-JCM-CWH
JOINT STIPULATION FOR EXTENSION
CROSS-MOTION TO AFFIRM
(First Request)

The parties request to extend the time by thirty-one days from September 11, 2015 to

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October 13, 2015 for Defendant Carolyn W. Colvin, Acting Commissioner of Social Security
(the Commissioner), to file her Cross-Motion To Affirm
request for an extension.1

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The Court granted the Commissioner an extension prior to filing her Answer because the
agency component responsible for producing the Certified Administrative Record had not yet
provided it. This occurred prior to briefing.
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There is good cause because

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workload and was attending full-day in-office training for two days and then was on approved

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leave. Further, counsel had a number of deadlines this week, including another District Court

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brief, and two more briefs due next week. The Commissioner needs additional time to respond

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to the is

For Reversal. Plaintiff has no objection.

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Respectfully submitted,
Date: September 11, 2015
By:

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Attorneys for Plaintiff

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/s/* Marc V. Kalagian
MARC V. KALAGIAN
*by email authorization on 9/10/15

Date: September 11, 2015

DANIEL G. BOGDEN
United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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By:

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/s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney

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Attorneys for Defendant

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IT IS SO ORDERED.
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DATE: September 14, 2015
THE HONORABLE C.W. HOFFMAN, JR.
United States Magistrate Judge
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DEFENDANT'S CERTIFICATE OF SERVICE

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I certify that I caused a copy of the Joint Stipulation For Extension Of Time

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Cross-Motion To Affirm to be served, via CM/ECF notification, on:

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MARC V. KALAGIAN
Law Offices of Rohlfing & Kalagian, LLP
211 East Ocean Boulevard, Suite 420
Long Beach, California 90802
[e-mail]
Date: September 11, 2015

DANIEL G. BOGDEN
United States Attorney
BLAINE T. WELSH
Chief, Civil Division

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/s/ April A. Alongi
APRIL A. ALONGI
Special Assistant United States Attorney

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Attorneys for Defendant

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By:

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