Gill v. Colvin

Filing 20

ORDER Granting 19 Joint Stipulation for Extension of Time to File Defendant's Cross-Motion to Affirm. (Second Request). Signed by Magistrate Judge Carl W. Hoffman on 11/17/15. (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]
DANIEL G. BOGDEN, NVBN 2137
United States Attorney
BLAINE T. WELSH
Chief, Civil Division
SUSAN L. SMITH, CSBN 253808
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant
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
OF TIME TO FILE DEFENDANT’S
CROSS-MOTION TO AFFIRM
(Second Request)

The parties request to extend the time by sixty days from October 13, 2015, nunc pro

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tunc, to December 14, 2015 for Defendant Carolyn W. Colvin, Acting Commissioner of Social
Security (the Commissioner), to file her Cross-Motion To Affirm. This is the Commissioner’s
second request for an extension to file her Cross-Motion.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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The extension is necessary because the previously assigned attorney for Defendant has

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unexpectedly been on leave due to a medical emergency. As a result of counsel’s unexpected

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and extended absence, Defendant inadvertently failed to file her Cross-Motion by the

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October 13, 2015 deadline. After discovering this, Defendant has had to reassign this case to

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another attorney. Therefore, Defendant needs additional time for newly assigned counsel to take

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over the case, become familiar with the issues, and complete briefing.

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Plaintiff has no objection. Defendant apologies for any inconvenience resulting from the
delay.

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Respectfully submitted,
Date: November 16, 2015

By:

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/s/* Marc V. Kalagian
MARC V. KALAGIAN
*by email authorization on 11/16/15
Attorneys for Plaintiff

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Date: November 13, 2015

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

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By:
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/s/ Susan L. Smith
SUSAN L. SMITH
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: November 17, 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 To File Defendant’s

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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: November 16, 2015

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

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/s/ Susan L. Smith
SUSAN L. SMITH
Special Assistant United States Attorney

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Attorneys for Defendant

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By:

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